1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

Details of the disposition

On June 2, 2014, Plaintiff A registered the business of the Housing Construction and Sales Business under the trade name “C” and closed the business on December 16, 2015.

Plaintiff

B On June 2, 2014, "D" registered the business of housing construction and sales business, and closed on December 16, 2015.

A building permit, approval for use, and sale of an officetel is a building with the size of 1st basement, 10 floors above ground, 1,647.90 square meters below the total floor area of 1,647.90 square meters on the land outside Busan Dong-gu, Busan, Dong-gu, and the construction permit of "F" (8 households of multi-household 2-5 stories and 6-10 households of officetels) was granted, and the approval for use was issued on March 25, 2015, and sold it in lots

(hereinafter) Ten households of the instant officetel 10 (hereinafter “Otel 1tel”). The Plaintiff Company: (a) obtained a building permit to newly construct “H” (8 households of multi-household 2-5 stories and 6-10 officetels 10 households), which is a building of the size of 1 stories underground, 10 stories above ground, 1,647.90 square meters in the land outside Busan Dong-gu, Busan; (b) obtained approval for use on March 25, 2015; and sold it in lots.

(hereinafter) Ten households of the instant officetels are “No. 2 officetels” and the said officetels are combined with “the instant officetels.” The Plaintiffs subject to the imposition of value-added tax, deeming the sales revenue of the instant officetels as eligible for the exemption of value-added tax, did not file a return and pay the relevant value-added tax.

On December 6, 2018, the Defendant deemed that the instant officetel supply does not constitute the supply of national housing exempt from value-added tax pursuant to Article 106(1)4 of the Restriction of Special Taxation Act, and notified the Plaintiffs of the correction and notification of value-added tax (including additional tax) for 2015 as indicated below.

(1) Plaintiff A, the first period of 110,198,523 11,019,852,222,039,704,497,957 183,756,756, 781,7564,818, 1759,636, 3515, 1515, 15,047,1627,683, 40 Plaintiff B, the first period of 64,525,9276, 52, 592, 905, 23, 788, 704, 197, 2015, 2015, 20197, 2009, 20197, 20197, 2019, 201, 2019