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1. Additional tax amounting to KRW 6,028,610,360, which the Defendant imposed on the Plaintiff on January 27, 2015, is KRW 702,982,830.
Reasons
1. Details of the disposition;
A. Two U.S. Comprehensive Development Co., Ltd. (hereinafter “the two U.S. Comprehensive Development”) purchased each land listed in the separate real estate list (hereinafter “instant land”) from around 2008 to around 2010 for the purpose of constructing a golf course of 18 holes in the area of 39-9, 110,024 square meters in the two Mancheon-si, the two Mancheon-si, the two Mancheon-si, the two Mancheon-si, the two Mancheon-si, the two Mandong-si, the two Mandong-si, and the two Man-si LLC-do, the Plaintiff entered into a real estate security trust agreement on the instant land with the first beneficiary as the Bank, the Korea Exchange Bank, and the two Man-si Don-si LLC-si, the ownership transfer registration under the Plaintiff’s name as the reason of the said trust
B. Following the completion of the instant golf course construction and the completion of new registration on the instant golf course on September 10, 2013, the Defendant paid acquisition tax and special rural development tax (hereinafter “acquisition tax, etc.”) following the change of land category on October 10, 2013 and April 7, 2014 by deeming the said new registration date as the acquisition date due to the change of land category.
C. From September 22, 2014 to December 26, 2014, the Defendant conducted a tax investigation into two undeveloped comprehensive development projects. As a result, a person liable to pay acquisition tax, etc. following a change of land category of the instant land was fully refunded acquisition tax, etc. returned and paid by the two undeveloped comprehensive development project on the ground that the two undeveloped comprehensive development was paid and paid acquisition tax, etc. as the trustee
Since then, the Defendant: (a) imposed and collected acquisition tax on the instant land as the tax base at KRW 53,256,275,413; (b) KRW 7,093,735,860 (including additional tax on negligent tax returns of KRW 1,065,125,500; and (c) KRW 702,861,030 (including additional tax on negligent tax of KRW 70,298,280) and special rural development tax; and (d) KRW 7,69,596,890,890 for the Plaintiff on January 27, 2015.
(c).