The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. As to the ground of appeal No. 1, Articles 120(1)12 and 119(1)13 of the Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010) (hereinafter “former Provisions of the Special Taxation Act”) provide that “acquisition tax shall be reduced by 50/100 on real estate acquired by a special purpose company by December 31, 2012 from an asset holder or another special purpose company, where the special purpose company takes over securitization assets from the asset holder or another special purpose company, or manages, operates, or disposes of the acquired securitization assets from the asset holder or another special purpose company, shall be reduced or exempted.” However, Article 120(1)9 of the Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “Special Provisions of the Act”) provides that acquisition tax shall be reduced or exempted by 0/100 on real estate acquired from the special purpose company.

In the meantime, Article 2(6) of the Addenda to the amended Special Provision provides that "the amended provision concerning acquisition tax under this Act shall apply from the portion first acquired after this Act enters into force," and Article 52 (hereinafter "the supplementary provision of this case") provides that "the local tax imposed, reduced, or exempted in accordance with the previous provision at the time this Act enters into force shall be governed by the previous provision as a general transitional measure."

(2) In a case where a tax law was amended disadvantageous to a taxpayer, the amended law has a transitional provision that “The tax to be imposed or exempted under the previous provisions at the time of enforcement of this Act shall be governed by the previous provisions”.