1. The lawsuit of the limited liability company specializing in the primary securitization shall be dismissed.

2. Plaintiff Asian Trust.

1. Details of the disposition;

A. On January 1, 2014, the enforcement date of the amended Local Tax Act (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Local Tax Act”), the Plaintiff trust company concluded a real estate trust agreement under the Trust Act (hereinafter “instant trust agreement”; and completed the trust registration of the instant trust property with respect to the instant trust property, with respect to 14 lots, including the 696 m2, Seosan-si, Yangsan-si, 780m2, etc. between the corporation and the corporation, which was placed before January 1, 2014.

B. The Plaintiff UPP Specialized Company (hereinafter “Plaintiff Special Purpose Company”) holds the right to preferential benefit under the instant trust agreement (the right to preferentially receive the principal and interest, etc. within the scope of the remaining amount obtained by subtracting the costs of disposal of trust affairs, trust remuneration, etc. from the proceeds of realizing trust assets).

C. On September 10, 2014, pursuant to Article 107(1)3 of the amended Act (hereinafter “instant provision”), the main text of Article 1 and Article 17(1) of the Addenda (hereinafter “instant Addenda provision”), the Defendant issued each disposition imposing property tax (land) 15,258,020 on the instant trust property, local education tax (hereinafter “instant disposition”) and local education tax (hereinafter “instant disposition”).

[Reasons for Recognition] Unsatisfy, Gap evidence 1, Eul evidence 1 and 2 (including virtual number), the purport of the whole pleadings

2. The plaintiffs' assertion

A. The supplementary provision of this case also applies to the trust contract concluded prior to the enforcement of the amended Act, thereby infringing on the property rights of the trustee and the beneficiary under the trust contract. Thus, it constitutes a petition-oriented legislation prohibited by Article 13(2) of the Constitution.

B. At the time of application of the former Act, the Plaintiffs are liable to pay property tax on trust property.