A. The Plaintiff is a company that owns each land and building (hereinafter collectively referred to as “influence real estate”) indicated in the “tax disposition details” on land, etc. in Jung-gu Seoul Metropolitan Government Joint 17-3 (Attached Form 1) and operates a “fluence hotel” as a special hotel in the key real estate.

B. The Plaintiff applied Article 54(2) of the former Restriction of Special Local Taxation Act (amended by Act No. 12175, Jan. 1, 2014); Article 54(2) of the Restriction of Special Local Taxation Act (hereinafter “former Act and the Restriction of Special Local Taxation Act”) and Article 27 of the Enforcement Decree of the Restriction of Special Local Taxation Act; Article 1112 of the former Ordinance on the Reduction and Exemption of Gu Taxes (amended by Ordinance No. 1112, May 7, 2012; hereinafter “former Ordinance on the Reduction and Exemption of Special Local Taxes”) to the Defendant’s real estate subject to the reduction and exemption of property tax for the reason that the Plaintiff set the passenger room charge by 20% or more from the display price standard on January 1, 2007.

C. On the other hand, the Plaintiff, from May 2010 to October 2010, opened up the entire hotel (i.e., remodeling; hereinafter “renovation”).

After the completion of remodeling, the Plaintiff adjusted the passenger room fee on the display price basis by taking into account other hotel room charges at the same level in around 2011, which is after the completion of remodeling, and then reduced the rate by 20% and applied it from January 1, 2012 to 2014.

On January 1, 2007, the Defendant: (a) on December 6, 2016, 2016, on the ground that the reduction rate of the passenger room fee of flass hotel falls short of 20%, which is the basis of property tax reduction compared to the passenger room fee as of January 1, 2007; and (b) on the real estate for which the Plaintiff was already reduced or exempted, such as the entry of the details of taxation disposition, property tax for the year 2012, 2013, and 2014