1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The reasoning of the judgment of the court of first instance is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, since the reasoning of the judgment of the court of first instance is identical to the reasoning of the judgment of the court of first instance, except for the dismissal of the following contents:

The 6th parallel 14 to 8th parallel 17th parallel are as follows:

In light of the following circumstances, it is reasonable to view that only the portion of the tourism brokerage fee among the ground expenses received by the Plaintiff from a foreign travelr constitutes a sale subject to zero tax rate. Therefore, the Plaintiff’s rejection disposition of this case is lawful, and the Plaintiff’s assertion on different premise is without merit. 1) Article 24(1)3 of the Value-Added Tax Act provides that the supply of goods or services acquired in foreign currency is subject to zero-rate tax rate in cases prescribed by Presidential Decree. Article 33(2)7 of the Enforcement Decree of the Value-Added Tax Act provides that “tourist brokerage service provided by a general travel enterprise under the Enforcement Decree of the Tourism Promotion Act shall be subject to zero-rate tax rate.” Article 33(2)1 (h) of the Enforcement Decree of the Value-Added Tax Act provides that “business facility management and business support service” shall be provided as the provision of services subject to zero-rate tax rate.

(Article 11(1)4 of the former Value-Added Tax Act and Articles 26(1)5 and 26(1)1(h) of the former Enforcement Decree of the Value-Added Tax Act are almost similar to the above provisions. Meanwhile, the application of zero tax rate under the Value-Added Tax Act is similar to the above provisions.