1. The plaintiff's claim is dismissed.

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

1. Basic facts

A. The Plaintiff is a corporation that operates the manufacturing business of printed circuit board, etc., and the Defendant is a corporation that manufactures and sells semiconductors and related products.

B. From April 2010 to the end of 2012, the Plaintiff transferred (hereinafter “instant transaction”) the printing circuit board for the print circuit board (hereinafter “printed circuit board”) equivalent to KRW 13,042,516,420 in total of the supply value to C (hereinafter “China”), which is the Defendant’s Chinese subsidiary (hereinafter “China”), and the following table is distinguishable by taxable period.

Tax period (unit of won: 2,897,350, 197 2,664,437,534 201 1, 201 3,429,665,249 2, 2011 2,3,042,516,420

C. The Plaintiff filed a value-added tax return by applying the zero tax rate on the grounds that the instant transaction constitutes an export transaction.

However, after conducting a consolidated investigation into the Plaintiff, the head of Ansan District Tax Office: (a) deemed that the instant transaction constitutes a domestic transaction between the Plaintiff and the Defendant; and (b) did not constitute “goods supplied by means of a local letter of credit or a written confirmation of purchase” under Article 11(1)1 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013; hereinafter the same shall apply); and (c) Article 24(2)1 of the former Enforcement Decree of the Value-Added Tax Act (amended by Presidential Decree No. 24359, Feb. 15, 2013; hereinafter the same shall apply); (b) deemed that the instant transaction constituted an additional tax of KRW 501,560,30 (including additional tax of KRW 211,825,271); (c) KRW 21,049,870, value-added tax of KRW 2315,2010 (including additional tax of KRW 253136,2505).

E. On March 9, 2016, the Plaintiff’s instant transaction to Suwon District Court is an export transaction between the Plaintiff and China C.