All appeals are dismissed.

Costs of appeal shall be borne by each party.

The grounds of appeal are examined.

1. Case history

A. From November 16, 2009 to November 16, 2015, the head of the Yeongdeungpo District Tax Office imposed the Plaintiff comprehensive real estate holding tax amounting to the portion reverted to the year 2009 to 2015. Each of the instant dispositions was imposed on the Plaintiff.

The Plaintiff paid all the comprehensive real estate holding tax imposed as above.

B. Articles 9(3) and 14(3) and (6) of the Gross Real Estate Tax Act provide that a certain amount of money equivalent to the “tax amount imposed as property tax” (hereinafter “tax amount subject to comprehensive real estate holding tax”) shall be deducted from the amount of comprehensive real estate holding tax.

In calculating the disposal tax amount of the comprehensive real estate holding tax, each disposition of this case calculated the deductible tax amount and calculated the deductible tax amount, and calculated the deductible tax amount in the calculation method in attached Form 3(2) of Article 5(2)3 of the Enforcement Rule of the Comprehensive Real Estate Holding Tax Act (hereinafter “instant Enforcement Rule formula”).

The formula is [Public Notice Price of Housing, etc. subject to Taxation - Taxation Standard Amount) 】 (Fair Market Price Ratio of Comprehensive Real Estate Tax 】 Property Tax fair market price ratio 】 Property Tax rate].

C. Meanwhile, Articles 4-2 and 5-3(1) and (2) of the former Enforcement Decree of the Gross Real Estate Tax Act (amended by Presidential Decree No. 26670, Nov. 30, 2015) which were applied at the time of each of the instant dispositions (hereinafter “the instant formula in the Enforcement Decree”).

The formula is [total amount of tax imposed as property tax on housing 】 amount equivalent to property tax calculated as the standard tax rate of property tax on housing ± amount equivalent to property tax calculated as the standard tax rate of property tax on housing ± amount equivalent to property tax calculated as the standard tax rate of

However, among the formula in the Enforcement Decree of the instant case, the “tax base of housing, etc.” stated in the molecule is the former Gross Real Estate Tax Act (amended by Presidential Decree No. 21293, Feb. 4, 2009).