1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

1. The reasons for the entry of this case by the court of first instance concerning this case are added to the following Paragraph 2, and the reasoning for the judgment of the court of first instance is the same as the reasons for the judgment of the court of first instance, except for the addition of the determination of a new argument made by the plaintiff in this court as set forth in Paragraph 3 below, and thus, it is acceptable as it is in accordance

(hereinafter the meaning of the terms used in this case is the same as the judgment of the court of first instance). 2. 3. Additional Part 4. 3. "Therefore, the confirmation of the parties to the transaction under the Value-Added Tax Act shall be determined on the basis of whom the actual goods or services are provided under the substance over form principle. Even if the Plaintiff entered into a contract with A for goods supply, even if the Plaintiff actually supplied goods to B, the parties to the transaction of this case shall be B.

The following shall be added after the 8th sentence “Non-”:

The instant transaction is a transaction with no omission of value-added tax tax from the beginning. The Defendant’s arbitrary restructuring of the instant transaction to the Plaintiff’s multilevel transaction (Plaintiff AB) and imposing value-added tax on which the Plaintiff had no obligation to pay the Plaintiff at the beginning would seriously undermine the stability of the transaction and the predictability of tax payment. The following is added after the 12th page 13 of the “The instant transaction.”

Article 6(1) of the former Value-Added Tax Act provides that the supply of goods subject to taxation is “the delivery or transfer of goods by contract or legal grounds.” The delivery or transfer of goods in this context must ultimately involve the transfer of the right to use and consume the goods in light of the fact that the value-added tax is a kind of consumption tax. The mere provision of raw materials to a foreign contractor for the purpose of processing is a taxable cause of value-added tax.