1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The Plaintiff has installed and operated a substation with a total floor area of at least 500 square meters on the ground, which is a residential area designated by the National Land Planning and Utilization Act (hereinafter “National Land Planning Act”) in order to supply electricity to the two-dong areas of Dobong-gu Seoul Metropolitan Government (hereinafter “instant substation”).

B. From 2001 to 2010, the Defendant: (a) deemed the instant substation as a “factory building” under Article 111(1)2 (b) of the Local Tax Act; and (b) applied the tax rate of 5/1,000; (c) imposed property tax and local education tax thereon; (d) from 2011 to 2016, the Defendant applied the tax rate of 2.5/1,000 corresponding to the “other buildings” under Article 111(1)2 (c) of the Local Tax Act to the instant substation, and imposed property tax and local education tax accordingly.

C. From 2011 to 2016, the Defendant imposed property tax by applying the tax rate of 2.5/1,00 to the instant substation is erroneous and omitted. The instant substation constitutes “factory building” under Article 111(1)2(b) of the Local Tax Act, and thus, the tax rate of 5/1,00 should have been applied to the Plaintiff on February 10, 2017. As indicated in the attached list, the Plaintiff imposed property tax and local education tax omitted based on the amount of property tax calculated by applying the tax rate of 5/1,00 to the property tax base of the instant substation from 2012 to 2016, as indicated in the attached list, and imposed local education tax on the Plaintiff on the Plaintiff on the ground that the instant substation falls under “factory” under Article 146(2)2 of the Local Tax Act and Article 138(1)2(g) of the Enforcement Decree of the same Act.

(hereinafter referred to as “instant disposition” in total, including the above imposition of property tax, local education tax, and local resource and facility tax.

The plaintiff appealed against this and filed a request for a trial with the Tax Tribunal on June 2017.