1. The part of the acquisition tax imposed by the Defendant against the Plaintiff on July 4, 2013, which was KRW 5,760,040,000, additional tax of KRW 560,040, and local education tax of KRW 576.

1. Details of the disposition;

A. On November 10, 201, the Plaintiff was a special purpose company established pursuant to Article 2 subparag. 5 of the Asset-Backed Securitization Act, and acquired, on December 2, 201, securitization assets, including loan claims secured by A apartment 101 Dong 2002, Gwangju City (hereinafter “instant real estate”), from the bank, the asset holder, in KRW 133.1 billion.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate and received a decision to permit the sale of the instant real estate as the purchaser on April 9, 2012, and paid the sale price in full on May 25, 2012.

C. The Plaintiff reported and paid acquisition tax of 50 million won, local education tax of 5,200,000 won, local education tax of 520,000 won, and special rural development tax of 260,000 won, calculated by reducing and exempting tax amount of 50/100 pursuant to 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 Act”); and

On July 4, 2013, the Defendant deemed that the acquisition of the instant real property does not fall under those subject to reduction or exemption of acquisition tax under the former Act, and imposed the Plaintiff local education tax including acquisition tax of KRW 5,760,040 including penalty tax of KRW 560,040 and penalty tax of KRW 576,000 including penalty tax of KRW 56,000, and penalty tax of KRW 28,000, total amount of KRW 6,624,040 including penalty tax of KRW 28,00.

(hereinafter “Disposition in this case”). / [Grounds for recognition] without dispute, Gap evidence Nos. 1, Eul evidence Nos. 2 and 3, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion (1) contrary to the principle of trust protection is that acquisition tax shall be reduced by 50% when a company manages, operates, or disposes of the acquired securitization assets from a special purpose company even if the new law is applied from the Seoul Special Metropolitan City Treasury’s taxation department.