1. The Defendant imposed the acquisition tax of KRW 4,568,479,580 on the Plaintiff on December 21, 2012, and the local education tax of KRW 843,969,410 on the Plaintiff.

1. Details of the disposition;

A. The Plaintiff is a corporation that manufactures and sells cement products.

B. On October 21, 2011, the Plaintiff purchased ready-mixed and debrising manufacturing company (hereinafter “instant factory”) located in YY-dong, Samcheon-gu, Samcheon-si (hereinafter “Seongyang-dong”) from Sungyang-si Co., Ltd. (hereinafter “Seongyang-dong”) for KRW 107 billion.

The details of the purchase contract are as follows:

Land subject to sale and value - Land (45-2 et al., 45-2 et al., 19): 81,341,095,00 won - 6 operation of factory buildings : 5,580,233,00 won - 4,483,134,000 won - 109 items of structures, such as cement mortar: 109 items of machinery and apparatus: 15,595,538,000 won for all kinds of machinery and apparatus: the objects subject to transfer under this contract shall include the land, buildings, structures, fixtures and other assets exclusively or mainly used or used for the manufacture and sale of ready-mixed and sloping of the factory, unless it is excluded from paragraph 2.2 below.

2.2. The object to be excluded from the transfer: All contractual relations, all claims and liabilities under the Acts and subordinate statutes of the Sungyangyang Society concluded with a business partner, etc. in connection with the factory business, all the labor relations and inventory assets concluded with the factory employee of the case;

C. According to the acquisition of the factory of this case, the trade name and representative of the factory were changed from the Seongbuk-do Council to the Plaintiff.

On November 14, 2011, the Plaintiff reported and paid 4,009,273,130 won (general tax rate of 4%), including acquisition tax, for land and buildings among the instant factories, and 96,152,260 won (general tax rate of 2%) including acquisition tax, for facilities.

However, the Defendant, on December 21, 2012, deemed that the acquisition of the instant factory site and building constitutes real estate following the establishment of a branch in a large city as prescribed by Article 27(3) of the Enforcement Decree of the Local Tax Act (hereinafter “the Act”), and thus, applied the heavy tax rate of 8% to the land and building, acquisition tax (including additional tax) for the land and building, 4,568,479,580 won, and additional tax for local education tax.