The defendant's acquisition tax on March 15, 2019 2,972,11,50 won, additional tax 1,630,946,180 won, and special tax for rural development.

1. Details of the disposition;

A. The Plaintiff is a corporation that runs an insurance business that can be run under the Insurance Business Act and the relevant laws and regulations and is engaged in business incidental thereto.

B. On November 27, 2014, the Plaintiff newly constructed and acquired a building C (hereinafter “instant building”) consisting of two identical buildings of a total floor size of 35,05.07 square meters (the total floor area was changed to 35,103.58 square meters by additional extension) in Yongsan-gu, Yongsan-gu, Seoul (hereinafter “instant building”).

C. On January 19, 2015, the Plaintiff reported acquisition tax of KRW 2,96,882,650 calculated by applying the general tax rate under Article 11(1)3 of the former Local Tax Act (amended by Act No. 13636, Dec. 29, 2015; hereinafter the same) to the Defendant, based on the acquisition price of the instant building as the tax base of KRW 94,838,059,259,253, and paid it on the 26th of the same month.

On September 11, 2015, the Defendant corrected acquisition tax on the reduced contract amount due to the amendment to the new construction contract of the instant building, and refunded KRW 29,69,690 to the Plaintiff.

Gyeonggi-do conducted a tax investigation with regard to the Plaintiff, and notified the Defendant on December 20, 2018 that the heavy tax rate under Article 13(1) of the former Local Tax Act should apply to the building newly built by the instant building for the business purposes of the Plaintiff’s head or main office.

E. On February 12, 2019, the Defendant notified the Plaintiff of taxation of acquisition tax of KRW 4,593,226,960 (including additional taxes) and special rural development tax of KRW 433,327,620 (including additional taxes) calculated by applying the heavy taxation rate under Article 13(1) of the former Local Tax Act as the tax base of the acquisition value of the entire building of the instant case.

The plaintiff appealed against this and applied for pre-assessment review, and the Governor of the Gyeonggi-do decided to partially adopt that the heavy tax rate shall not apply to the area leased to others for convenience stores and carpets among the buildings in this case.

F. On March 15, 2019, the Defendant rendered a decision on pre-assessment review to the Plaintiff.