A. On June 8, 2011, the Plaintiff acquired securitization assets, such as loan claims, etc. secured by a special purpose company established for the purpose of taking over and transferring securitization assets pursuant to Article 2 subparagraph 5 of the Asset-Backed Securitization Act (hereinafter “Asset-Backed Securitization Act”) and for the management, operation, and disposal of securitization assets through an asset management company, which was acquired by transfer from the asset holder under subparagraph 2 of Article 2 of the Asset-Backed Securitization Act (hereinafter “instant real estate”). < Amended by Act No. 1041, Oct. 28, 2010>

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure for the instant real estate, and received a decision to permit the sale of the instant real estate as the purchaser on January 9, 2012, and paid the sale price in full on February 3, 2012.

C. On March 9, 2012, the Plaintiff reported and paid acquisition tax, local education tax, and special tax for rural development, calculated by reducing or exempting 50/10 of the tax amount pursuant to Articles 119(1)13 and 120(1)12 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”) with respect to the instant real estate to the Defendant.

On September 19, 2014, the Defendant imposed acquisition tax of KRW 66,052,760, local education tax of KRW 6,154,910, and special rural development tax of KRW 2,852,270,059,940 on the Plaintiff on the ground that the Plaintiff’s acquisition of the instant real property does not constitute reduction or exemption under Article 120(1)9 of the Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “new Act”).

(hereinafter “Disposition in this case”). / [Grounds for recognition] without dispute, entry of Gap evidence Nos. 1 and 2, and purport of the whole pleadings

2. Whether the instant disposition is lawful

A. Articles 119(1)13 and 120(1)12 of the former Act applicable to the Plaintiff’s claim for reduction of acquisition tax pursuant to the interpretation of Article 120(1)9 of the former Act is a special purpose company.