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(영문) 서울행정법원 2015.05.22 2014구합70327

재산세등부과처분취소

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1. The lawsuit of the limited company specializing in the third-party securitization shall be dismissed.

2. The Plaintiff Han Bank.

Reasons

1. Details of the disposition;

A. On or before January 1, 2014, before the enforcement date of the Local Tax Act (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Local Tax Act”), the Plaintiff Han Bank (hereinafter “Plaintiff Han Bank”) concluded a real estate trust agreement under the Trust Act (hereinafter “instant trust agreement”) with the central government on the value of 340 to 234 square meters in Jongno-gu, Seoul, Jongno-gu, Seoul (hereinafter “instant trust agreement”) with the company engaging in real estate trust business, etc., and completed the trust registration on the instant trust property.

B. Under the Asset-Backed Securitization Act, the Plaintiff-based limited company specializing in the third-party securitization (hereinafter “Plaintiff-backed securitization company”) is the first beneficiary under the instant trust agreement (the beneficiary is entitled to preferentially receive the principal and interest within the scope of the remaining amount obtained by subtracting the disposal costs and trust remuneration, etc. from the proceeds of realizing trust assets, and the claims of the senior right holder) from the proceeds of realizing trust assets.

C. In accordance with Article 107(1)3 of the amended Act, the main sentence of Article 1 and Article 17(1) of the Addenda (hereinafter collectively referred to as the “instant Addenda provisions”), the Defendant imposed property tax on the Plaintiff Han Bank, which is the trustee of the instant trust property on September 10, 2014, KRW 1,921,370 of the property tax on the land of the instant trust property, KRW 9,970 of the urban area, KRW 9,970 of the local education tax, and KRW 384,270 of the local education tax.

(hereinafter “Disposition in this case”). / [Grounds for recognition] without dispute, entry of Gap evidence No. 1, the purport of the whole pleadings

2. The person liable to pay the property tax on the trust property claimed by the plaintiffs is changed from the truster to the trustee for about 20 years after it was newly established on December 27, 1993.