A. On December 29, 2008, the Plaintiff obtained approval from the Defendant for a housing construction project plan with the purport of “civil engineering construction business, electrical construction business, dredging construction business, etc.” (hereinafter “instant multi-family housing”) to build a soft apartment (613 households; hereinafter “instant multi-family housing”).

B. The Plaintiff paid each of the Defendant KRW 1,237,74,000 on November 23, 2009, and KRW 202,480,00 on February 22, 2010.

C. On March 30, 2012, the Plaintiff obtained a provisional use approval for the instant collective housing from the Defendant. On May 22, 2012, the Plaintiff reported and paid KRW 2,827,836,630 of the instant collective housing acquisition tax, and KRW 161,590,660 of the local education tax, by reflecting the construction cost, etc. required for the new construction of the instant collective housing.

From November 25, 2013 to November 29, 2013, the Special Self-Governing Province Governor notified the Plaintiff of the results of the tax investigation to the effect that the aggregate of KRW 777,414,110, including registration tax and property tax, should be collected.

As a result of the Plaintiff’s request for pre-assessment review, the amount of tax additionally collected was corrected to 22,009,300 won, and the Plaintiff paid 22,009,300 won additionally to the Defendant on February 28, 2014.

E. On December 11, 2015, the Ministry of the Interior rendered authoritative interpretation that “The charges for school sites paid during the process of acquiring real estate constitutes acquisition price which serves as the tax base for acquisition tax under Article 18(1) of the Enforcement Decree of the Local Tax Act” (hereinafter “instant authoritative interpretation”).

F. On September 26, 2016, the Defendant should include KRW 1,440,224,00,00, which was already paid by the Plaintiff on the acquisition price of the instant multi-family housing in the acquisition price of the instant multi-family housing. As such, the increased acquisition tax amount of KRW 51,00,620, and local education tax amount of KRW 2,683.