The judgment below is reversed and the case is remanded to Seoul High Court.

The grounds of appeal are examined.

1. As to the grounds of appeal Nos. 1 and 2

A. Articles 120(1)12 and 119(1)13 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Special Provision”) provide that “acquisition tax shall be reduced by 50/100 on real estate acquired by a special purpose company by transfer from an asset holder or another special purpose company, or by transfer from an asset holder or another special purpose company by December 31, 2012 when the special purpose company takes over securitization assets in accordance with an asset-backed securitization plan.” However, Article 120(1)9 of the Restriction of Special Taxation Act (amended by Act No. 10406, Jan. 1, 2011; hereinafter “Special Provision on Special Provision on Special Taxation”) provides that “acquisition tax shall be reduced by 50/100 on real estate acquired by transfer from an asset holder or other special purpose company” to be excluded from acquisition tax on real estate management, operation, and acquisition tax shall be reduced by 50/10/10.”

In the meantime, Article 2(6) of the Addenda to the amended Special Provision provides that "the amended provision concerning acquisition tax under this Act shall apply from the portion first acquired after this Act enters into force," and Article 52 (hereinafter "the supplementary provision of this case") provides that "the previous provision shall apply to the local tax imposed, reduced, or exempted under the previous provision at the time this Act enters into force, or to be imposed, or exempted" as a general transitional measure.

B. Where a tax law amended disadvantageously to a taxpayer, the Addenda to the amended law provides that “any tax to be imposed or exempted pursuant to the previous provisions at the time this Act enters into force shall be governed by the previous precedents,” which shall be applied to the taxpayer.