A. On November 29, 2013, the Plaintiff, a trust business entity establishing a real estate investment trust, concluded a trust agreement (title is “C”; hereinafter “instant investment trust agreement”) with the Plaintiff, a collective investment business entity, which is a collective investment business entity, with the content that “The instant collective investment business entity trusts the Plaintiff with collective investment property, and the Plaintiff invests and manages the collective investment property trusted in accordance with the instructions of the instant collective investment business entity, and invests the collective investment property in real estate and securities related to real estate in excess of 50/100 of the collective investment property.”

B. On December 4, 2013, the Plaintiff filed a return on acquisition of real estate and acquisition tax, etc. on December 4, 2013, pursuant to the instant investment trust agreement, Jongno-gu Seoul Metropolitan Government Land and its ground buildings (hereinafter collectively referred to as “instant real estate”).

(2) The Plaintiff acquired the instant real estate. (2) The Plaintiff reported and paid 30/100 of the tax amount of each of the instant real estate to a trust business entity under Article 120(4)2 of the former Restriction of Special Taxation Act (amended by Act No. 12853, Dec. 23, 2014; hereinafter “the former Restriction of Special Taxation Act”) on the ground that the acquisition of the instant real estate constitutes “the acquisition of real estate as collective investment property of a real estate fund under the Financial Investment Services and Capital Markets Act by December 31, 2014,” see Article 5(1)6 of the Act on Special Rural Development, Article 151(1)1(b) of the former Local Tax Act (amended by Act No. 12153, Jan. 1, 2014); and (c) a collective investment business entity, a truster, under the Financial Investment Services and Capital Markets Act, to a trust business entity under Article 151(1)1(b)1 of the same Act.