A. The Plaintiff, a special purpose company established pursuant to the Asset-Backed Securitization Act on November 29, 201, acquired securitization assets in KRW 269.9 billion from the Industrial Bank of Korea, the asset holder of which, on December 20, 201, via the security of land 275, located in Gyeong-gun, Busan, the Industrial Bank of Korea, the asset holder, and its ground buildings (hereinafter “instant real estate”).

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate in order to recover the said loan claims and subsequently paid the sales price on May 31, 2012 upon receiving the decision to permit the sale on June 19, 2012.

C. On July 31, 2012, the Plaintiff reported and paid acquisition tax, local education tax, and special rural development tax, calculated by deducting 50/100 of the tax amount pursuant to Articles 120(1)12 and 119(1)13 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”) on the basis of acquisition tax amount of KRW 894,139,683 with respect to the instant real estate as the tax base.

On May 10, 2013, the Defendant deemed that the acquisition of the instant real estate does not fall under those subject to reduction or exemption of acquisition tax, and imposed acquisition tax on the Plaintiff (including additional taxes) on the sum of KRW 23,202,910, Local Education Tax 2,141,440, and Special Rural Development Tax 981,300 (including additional taxes).

(hereinafter “Disposition in this case”). [Grounds for recognition] The Disposition in this case is without dispute, Gap evidence 1, Eul evidence 1 through 7 (including paper numbers) and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) Allied Asset Management Co., Ltd., which established the Plaintiff in violation of the principle of trust protection (hereinafter “Allied Asset Management”).

Even if the new law is applied from the Seoul Special Metropolitan City Treasury Tax Department, a special purpose company shall respond to an auction in the course of managing and operating the right to collateral on the basis of the claims acquired from the originator.