All appeals are dismissed.

Costs of appeal shall be borne by each party.

The grounds of appeal are examined.

1. Plaintiff’s ground of appeal No. 1 and Defendant’s ground of appeal

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 Taxation Act”) provide that “acquisition tax shall be reduced by 50/100 on real estate acquired by a special purpose company by December 31, 2012 when the special purpose company takes over securitization assets from an asset holder or another special purpose company, or manages, operates, or disposes of the acquired securitization assets from an asset holder or another special purpose company, 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, Dec. 27, 2010; hereinafter “Special Taxation Act”) provides that “acquisition tax shall be reduced or exempted for real estate acquired by a special purpose company from another special purpose company or from another special purpose company pursuant to an asset-backed securitization plan.”

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 local tax imposed, reduced, or exempted in accordance with the previous provision at the time this Act enters into force shall be governed by the previous provision as a general transitional measure."

B. In the event of an amendment of a tax statute, the law at the time when the tax liability is established, among the statutes before and after the amendment, should be applied. However, the tax law is disadvantageous to the taxpayer.