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. Basic facts

A. (1) The Plaintiff is a comprehensive accounting consulting company located in the German Frankfurt Ma. (2) The Plaintiff agreed with the Defendant to provide services as an agency for the refund of value-added tax in the European region, and concluded a service contract with the Defendant for the period from July 1, 2007 to June 30, 2009, with respect to the refund of the year 2007 and 2008 from October 5, 2007, with respect to the period of contract from July 1, 2007 to June 30, 2009, with respect to the refund of the year 209 from July 1, 2009 to June 30, 2010 to June 30, 2011.

(1) As of the fiscal year of value-added tax (hereinafter “value-added tax subject to refund”), according to the above agency contract: (a) as of the fiscal year of value-added tax to be refunded, the Plaintiff: (b) as of the pertinent agency contract, the Plaintiff shall prepare a report on the amount of refund within 14 days from the date of refund to the Defendant; and (c) shall submit the report to the Defendant; and (b) shall provide all prior advice to confirm whether the statement of transaction meets the requirements for the application for the refund of value-added tax; (c) the Plaintiff shall confirm whether the statement of transaction meets the requirements for the application for the refund of value-added tax; and (d) provide all kinds of advice to maximize the refund of value-added tax (Article 2 subparag. 1); (d) the Plaintiff shall respond to consultation on general tax and accounting arising in relation to the performance of duties at the Defendant’s request; and (e) request for the refund of value-added tax to the tax office of the European country delegated by the Plaintiff (Article 2 subparag. 2). 2).