A. The Plaintiff is a local public enterprise established with the aim of contributing to the stability of people’s lives by ensuring smooth distribution of agricultural and fishery products and maintaining and supplying adequate prices as prescribed by the Local Public Enterprises Act, the Act on Distribution and Price Stabilization of Agricultural and Fishery Products, and the Seoul Metropolitan Government Ordinance on the Establishment and Operation

B. On June 30, 2015, the Plaintiff newly built and acquired “B” buildings with a total floor area of 210,957.93 square meters, as indicated in the table below, in Songpa-gu Seoul (hereinafter “instant building”).

The business of managing 124,933.5 square meters B3 or 4-story 124,93.5 square meters or 122 m2,92.92 m2 or 18 m2, the business of managing facilities located in the facilities located in the wholesale and retail store (Adong) 6,612.5 m23 or 3 m253.28 m2,000 m26,071.61 B3 or 4 m23 or 6,023.15 m2 m2,070 m2,070 m210,957.93 m2

C. On August 18, 2015, the Plaintiff, upon filing an application for reduction or exemption under Article 15(2)1 of the Restriction of Special Local Taxation Act, acquired the entire building area of the instant building to use directly for its original purpose, was subject to reduction or exemption of KRW 8,561,586,068,00,541,862,00, special rural development tax, and KRW 433,489,60,00 in total, and KRW 8,561,419,60 in relation to the acquisition of the said building.

On July 15, 2016, the Defendant notified the Plaintiff of the results of the tax investigation that the portion of 79 mal rooms leased to the Plaintiff for the use of a restaurant bank hospital, pharmacy, etc. (hereinafter “instant key facilities”) and 15,263.91m2 (hereinafter “instant public room”) remaining in the public room until one year after the date of acquisition of the instant building, which are not directly used for the Plaintiff’s own business and are subject to collection of acquisition tax, etc. under Article 178 subparag. 1 of the Restriction of Special Local Taxation Act.

E. Accordingly, the Plaintiff filed a request for pre-assessment review with the Mayor of Seoul Special Metropolitan City on August 12, 2016, and the Mayor of Seoul Special Metropolitan City on October 4, 2016.