A. The Plaintiff is a corporation established to conduct real estate trust and real estate development business related thereto with authorization pursuant to the Financial Investment Services and Capital Markets Act.

B. On March 21, 2017, the Defendant concluded a land trust agreement (hereinafter “instant project agreement”) and a sale-type land trust agreement (hereinafter “land trust agreement”) with the Plaintiff on the land of Jin-si, Jin-do (hereinafter “instant land”) for the construction and sale of the land of the second underground floor, the knowledge industry center (factory) of the 12th floor above the ground, the neighboring living facilities (support facilities) on the ground (hereinafter “instant project”). On March 21, 2017, the Defendant entrusted the instant land to the Plaintiff as a truster, and the Plaintiff received registration of the instant land trust agreement on March 21, 2017, as a trustee under the instant land trust agreement, on which the instant land was registered based on the trust agreement.

C. Article 35(1) of the Land Trust Contract of this case provides, “At the same time, the truster (Defendant) shall register the business at the tax office having jurisdiction over the location of the trust real estate in accordance with the relevant tax laws.

Paragraph 2 of the same Article provides that "The value-added tax, etc. that is refunded to the business operator under paragraph 1 shall be comprehensively transferred by the trustee (Plaintiff)."

Article 12(1) of the Special Agreement on the Land of this case provides that “A truster shall notify the trustee’s tax office having jurisdiction over the trustee of the transfer of the national tax refund at each time when he/she files a value-added tax return related to the trust business, and where he/she receives a national tax refund directly, he/she shall immediately return the relevant amount of refund for the trust business to the trustee’s trust account.

Section 2 of the same Article provides that “A truster shall be.”