1. The acquisition tax paid by the Defendant to the Plaintiff on March 19, 2015, KRW 543,678,260, and additional tax for KRW 325,50,170, and local education tax for KRW 31,067.

1. Details of the disposition;

A. On May 30, 201, the Plaintiff built and acquired the K non-life insurance human resources learning housing (hereinafter “instant building”) that is a building on the ground, located in 78-1 land and located in 7 lots of land, in the Dacheon-si, Sacheon-si, Sacheon-do.

B. On July 5, 2011, the Plaintiff verified that the sum of energy performance index points (hereinafter “energy performance score”) from the Creviz Accreditation Accreditation Board, a certification institution for environment-friendly buildings, was 81.2, and was certified as the most excellent eco-friendly building.

C. Based on the foregoing certification result, the Plaintiff reported and paid acquisition tax, special rural development tax, total amount of local education tax, total amount of KRW 5,630,953,380 on July 27, 201, by applying Article 47(2) of the former Restriction of Special Local Taxation Act (amended by Act No. 11138, Dec. 31, 201; hereinafter the same shall apply) and Article 24(3)1(b) of the former Enforcement Decree of the Restriction of Special Local Taxation Act (amended by Presidential Decree No. 23484, Dec. 31, 2011; hereinafter the same shall apply) by 10/100 of the acquisition tax reduction rate prescribed in Article 24(3)1(b) of the former Enforcement Decree of the Restriction of Special Local Taxation Act (hereinafter the foregoing

On March 19, 2015, the Defendant determined that the provision on reduction or exemption of the instant building cannot be applied to the Plaintiff’s acquisition of the instant building, since the energy performance rating of the Crevis Certification Board submitted by the Plaintiff was not confirmed by an agency publicly notified by the Ministry of Land, Infrastructure and Transport. The Defendant issued a disposition imposing acquisition tax including reduction or exemption of the term portion and additional tax, special rural development tax, 62,084,160 won, local education tax, and 46,560,590 won (hereinafter “instant disposition”).

E. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on May 28, 2015, but the Tax Tribunal dismissed the Plaintiff’s appeal on September 23, 2015.

[Ground of recognition] Facts without dispute, entry of Gap evidence 2, 3, 5, and 8, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion 1 tax reduction or exemption

When interpreting a case, it is a question of law.