1. Revocation of the first instance judgment.

2. The Defendant’s local tax of KRW 10,945,240, which was imposed on the Plaintiff on October 10, 2012, and reverted to the year 2011.

1. Basic facts

A. The Plaintiff is a public corporation established by the Korea Highway Corporation with the aim of promoting road maintenance and contributing to the development of road traffic through the construction and management of roads and other projects related thereto. The Plaintiff is the owner of the said parcel of land (hereinafter referred to as “the said parcel of land”) in Gyeyang-si, Yangsan-si, 1054-3 large 275 square meters, 105-4 large 1,972 square meters per annum, 1085-4 large 13,454 square meters per annum, 1086 large 14,448 square meters per annum, 1088 large 108-1 large 595 square meters per annum, 1088-2 large 203 square meters per annum (hereinafter referred to as “the said parcel of land”).

B. The land No. 1 is a building for the office of the two mountainous districts owned by the Plaintiff (hereinafter “instant building”), parking lots, garages, maintenance depotss, storages, tenniss, tenniss, landscaping facilities, and legal surface. The land No. 2 includes landscaping facilities, legal surface, etc.

C. On October 10, 2012, the Defendant imposed imposition of KRW 46,582,940 of the local tax belonging to year 2011 (=property tax amounting to KRW 40,628,690 of the local education tax), KRW 46,717,920 of the local tax belonging to year 2012 (= property tax amounting to KRW 40,746,746,230 of the local education tax) on the land attached to a building under Article 106(1) of the former Local Tax Act (amended by Act No. 11617, Jan. 1, 2013; hereinafter the same shall apply) and Article 101 of the Enforcement Decree of the Local Tax Act.

On April 22, 2013, the Plaintiff filed an appeal with the Tax Tribunal. On February 6, 2014, the Tax Tribunal rendered a decision that “The Tax Tribunal excluded the site of the instant building from the land subject to property tax, the parking lot site, the Rotterdam site, and the area other than the area of the site of the landscaping facility from the land subject to property tax, thereby revising the tax base and tax amount.”

E. Accordingly, the Defendant imposed and notified the Plaintiff on March 6, 2014 by reducing KRW 19,940,920 of the local tax reverted to year 201, and KRW 19,996,650 of the local tax reverted to year 2012, upon the decision of the Tax Tribunal.

F. The Plaintiff on April 10, 2014.