In a preliminary ruling, the Tax Law Board has considered that the care agreement that a company had with a region did not mean that the company sold services to the region. The care agreement with the region meant that the company would provide medical care to patients. The patients paid a small part of the compensation for the care to the company, or not any part of the compensation, and the region paid the remaining part of the compensation according to agreement. According to the Tax Court, the company could not be considered to have traded any services to the region because there was no mutual exchange of services in a legal relationship between the company and the region. The company did not provide any services to the region, but the company provided services to the patients in the form of healthcare in accordance with the care agreement.. The compensation that the region paid according to the agreement was considered to constitute a third-party payment for the healthcare exempt from tax (SRN no. 26-20 / I).