1. Acquisition tax assessed against the Plaintiff on December 13, 2013, KRW 809,677,920, local education tax, and KRW 73,815,790, which was assessed against the Plaintiff.

1. Details of the disposition;

A. On August 9, 2013, the former Financial Investment Services and Capital Markets Act (amended by Act No. 13448, Jul. 24, 2015; hereinafter “former Financial Investment Services and Capital Markets Act”) concluded a contract to establish a privately placed real estate investment scheme (title: C; hereinafter “instant collective investment scheme”) in the form of investment trust under the former Financial Investment Services and Capital Markets Act (hereinafter “instant investment trust contract”) with the Plaintiff, a trust business entity under the former Financial Investment Services and Capital Markets Act.

B. In accordance with the instant investment trust agreement, the Plaintiff purchased a total of 1,063 square meters of land with a total of 102 square meters of land (hereinafter collectively referred to as “instant real estate”) including 509 square meters, including trust principal and other collective investment property paid from investors on August 13, 2013, as collective investment property, and completed the registration of ownership transfer in the name of the Plaintiff on August 27, 2013.

C. On August 14, 2013, Nonparty 2 filed an application with the Governor of the Financial Supervisory Service for registration of the instant collective investment scheme, and on August 29, 2013, the registration of the instant collective investment scheme was accepted.

On August 26, 2013, the Plaintiff filed an application for acquisition tax reduction or exemption with the following grounds: (a) the instant real estate constitutes “real estate acquired as collective investment property of a real estate fund under the Financial Investment Services and Capital Markets Act” under Article 120(4)2 of the former Restriction of Special Taxation Act (amended by Act No. 12853, Dec. 23, 2014; hereinafter the same) and applied for acquisition tax reduction or exemption; and (b) the acquisition tax, local education tax, and special tax reduced or exempted by 30% of the amount of tax, such as acquisition tax, was paid, respectively.

E. After that, the Defendant, on December 13, 2013, on the ground that the instant collective investment scheme was not completed at the time the Plaintiff acquired the instant real estate, and thus, the instant provision cannot be applied.