A. From Jun. 16, 2015, the Plaintiff: (a) purchased the instant land in KRW 12,516,094,000 for purchase price; (b) paid KRW 1,251,609,400 for the intermediate payment and remainder on September 9, 2015 and KRW 11,264,684,600 for the land development project, which was implemented on June 21, 2016.

On August 3, 2015, the Plaintiff obtained approval to establish a knowledge industry center which engages in urban factories on the ground of the instant land pursuant to Article 28-2 (1) of the Industrial Cluster Development and Factory Establishment Act (hereinafter “Industrial Cluster Act”).

(hereinafter the above knowledge industry center is "the knowledge industry center of this case" and the above approval for establishment is "the approval for establishment of this case". B.

On September 8, 2015, the Plaintiff changed the approval for the establishment of the instant land trust and knowledge industry center (hereinafter “instant trust”) concluded a management-type land trust agreement (hereinafter “instant trust”) with the Korea Asset Trust Co., Ltd. (hereinafter “Korea Asset Trust”) whereby the Plaintiff is the truster and the beneficiary, and the Korea Asset Trust is the trustee.

On the other hand, on September 10, 2015, the Korea Asset Trust reported the commencement of the knowledge industry center of this case on September 11, 2015 (hereinafter “instant approval”), and completed on June 7, 2016, the knowledge industry center of this case on September 7, 2016.

C. On October 30, 2015, the Plaintiff imposed acquisition tax, local education tax, and special rural development tax following the acquisition of the instant land shall calculate the tax base based on the acquisition price of the instant land to the Defendant based on KRW 12,516,094,00.