Acquisition tax of 190,305,390 won (including additional tax) and local education tax of 24,531.6.

1. Details of the disposition;

A. On June 16, 2016, the Plaintiff, an agricultural company established for the purpose of distributing and processing agricultural products pursuant to Article 19 of the Act on Fostering and Supporting Agricultural and Fishing Enterprises, etc., purchased 5,922,00,000,000 won in total for 6,571 square meters (hereinafter “instant land”) and buildings on the instant land and buildings on September 18, 2016, as an agricultural company established for the purpose of agricultural products distribution and processing business, etc.

B. On November 18, 2016, the Plaintiff paid KRW 136,160,000 in total of acquisition tax, local education tax, and rural special tax, upon reduction of or exemption from 50/100 of acquisition tax of the instant land pursuant to Article 11(2) of the former Act on Special Cases concerning Local Tax (Amended by Act No. 14477, Dec. 27, 2016; hereinafter “former Act on Special Cases concerning Local Tax”).

(c)

On July 20, 2018, the Defendant: (a) deemed that the Plaintiff was not directly used for farming, distribution, and processing within one year from the date of acquisition of the instant land; and (b) imposed and notified the Plaintiff of KRW 280,303,950, local education tax, KRW 41,709,450, and KRW 2,745,770, and KRW 324,758,7770, and KRW 770, total of KRW 324,75, and KRW 770,00 (hereinafter “prior disposition of this case”) of the former Local Tax Act (Amended by Act No. 14475, Dec. 27, 2016) on the Plaintiff.

(d)

The Plaintiff, dissatisfied with the preceding disposition of this case, filed an objection with the Gyeonggi-do branch, filed an appeal with the Tax Tribunal, but all the appeals were dismissed, and all the acquisition tax imposed as above was paid.

E. On February 13, 2020, the Defendant confirmed that the Plaintiff did not directly use the remainder of 3,713 square meters (6,571 square meters - 2,858 square meters) of the instant land for the pertinent purpose without justifiable grounds, as a result of the local tax investigation, by the time one year has elapsed from the date of acquisition.