A. It is a trust business entity under the Plaintiff’s Capital Market and Financial Investment Services and Capital Markets Act. On April 22, 2010, it is a collective investment business entity as prescribed by the B Capital Market and Financial Investment Services and Capital Markets Act.

(1) The collective investment business entity of this case (hereinafter “instant collective investment business entity”) entered into a trust agreement with the Plaintiff that created a privately placed real estate collective investment scheme (title: C; hereinafter “instant collective investment scheme”) in the form of an investment trust under Articles 9(18)1, 9(19), and 188, and 229 subparag. 2 of the former Financial Investment Services and Capital Markets Act (amended by Act No. 11758, Apr. 5, 2013; hereinafter “former Financial Investment Services and Capital Markets Act”) with a collective investment business entity of this case (hereinafter “instant collective investment business entity”) to invest and manage collective investment property trusted to the Plaintiff in accordance with the instruction of the instant collective investment company.

(hereinafter “instant investment trust agreement”). B.

The Plaintiff acquired D, E, F, G land and buildings on the ground of D, E, and F ground (hereinafter collectively referred to as “instant real estate”) from among the above land, as collective investment property, including trust principal paid from investors on June 29, 2012 according to the instant investment trust agreement.

C. On July 19, 2012, the instant collective investment business entity filed an application for registration of the instant collective investment scheme with the Governor under the Capital Markets Act, and the instant collective investment scheme was registered as a real estate fund under the Capital Markets Act on July 30, 2012.

The Plaintiff is a real estate fund under the Financial Investment Services and Capital Markets Act, which is stipulated in Article 120(4)2 of the former Restriction of Special Taxation Act (amended by Act No. 11486, Oct. 2, 2012; hereinafter the same) (hereinafter “instant provision”).