The judgment of the court below is reversed, and the case is remanded to Daejeon High Court.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. According to Article 16(1) of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013), where an entrepreneur registered as a person liable for duty payment supplies goods or services, a tax invoice shall be issued to the person receiving the goods or services. Here, “person receiving the services” refers to the person receiving the services, etc. on contractual or legal grounds. As such, in determining who is a “person receiving the services” due to contractual grounds, all circumstances, such as the parties to the contract that caused the provision of the services and the contents thereof, the supply of the services is made for anyone, and the payment relationship thereof shall be taken into account.

(2) According to the reasoning of the judgment below and evidence duly admitted, the State established the former Framework Act on Railroad Industry Development as Act No. 6955 of July 29, 2003 to promote the structural reform of the railroad industry that separates the railroad facility sector from the railroad operation sector in order to strengthen the competitiveness of the railroad industry and build a development foundation, respectively, after establishing the former Framework Act on Railroad Industry Development as well as the former Framework Act on Railroad Industry Development as Act No. 6955 of July 29, 2003, integrating or integrating the relevant organizations of the existing Korea Railroad and the Korea Railroad Facilities Corporation, and converting them into their organization, the railroad facility sector has the Plaintiff act on behalf of the Plaintiff with regard to the construction and management of railroad facilities, including railroad tracks, and the railroad operation sector has the Korea Railroad Corporation carry out railroad operation projects, including railroad passengers and freight transportation.