안전한 바카라사이트

1. Overview of the Case

a. Party represented by Barun Law
Plaintiff A 안전한 바카라사이트., Ltd., which received a notice of assessment and payment on October 16, 2023, from the defendant tax authority, imposing a total of KRW 1,894,208,540 (including additional tax) in reduced acquisition tax, etc. pursuant to Article 178(1)1 of the Act on Restriction of Special Cases Concerning Local Taxation.

b. Background of the Case
On June 21, 2021, the plaintiff purchased the land at issue, and on July 8, 2021, received a 25% reduction in acquisition tax, etc. pursuant to Article 20(2) of the old Act on Restriction of Special Cases Concerning Local Taxation with respect to the portion of the land designated for use as a senior welfare facility.

However, following an on-site inspection of the land on July 17, 2023, the defendant determined that the plaintiff had failed, without justifiable grounds, to directly use the land for a senior welfare facility within one year from the date of acquisition. Accordingly, on October 16, 2023, the defendant assessed and notified the plaintiff of recaptured taxes pursuant to Article 178(1)1 of the Act on Restriction of Special Cases Concerning Local Taxation consisting of KRW 1,692,675,690 in acquisition tax, KRW 134,355,240 in local education tax, and KRW 67,177,610 in rural special tax, totaling KRW 1,894,208,540 (including additional tax).

The plaintiff filed a tax appeal challenging the disposition, but the Tax Tribunal dismissed the appeal on November 8, 2024.

c. Litigation Proceedings
The plaintiff filed this action against the defendant, seeking revocation of the disposition imposing acquisition tax, etc., on the grounds that the tax disposition to recapture the reduced acquisition tax, etc. pursuant to the Act on Restriction of Special Cases Concerning Local Taxation was unlawful.

2. Judgment

Suwon District Court Decision 2025GuHap61054, dated December 18, 2025

3. Grounds for the Judgment

The court held that, as the plaintiff acquired the land for the purpose of installing and operating a senior welfare facility, it was unlikely that the plaintiff could have extended the period for preparing the building permit; that it was difficult to conclude that the period required to obtain the building permit was delayed beyond the ordinary timeframe due to the plaintiff's negligence; and that the mere fact that the commencement report was filed somewhat late did not suffice to conclude that the plaintiff had failed to make genuine efforts to construct the building.

Accordingly, the court found that the plaintiff had made normal and diligent efforts to directly use the land for a senior welfare facility, but that the grace period had elapsed due to the time required for essential administrative procedures. The court therefore held that "justifiable grounds" under Article 178(1)1 of the former Act on Restriction of Special Cases Concerning Local Taxation existed and rendered a judgment revoking the disposition imposing acquisition 안전한 바카라사이트, etc. on the plaintiff.

4. Our Arguments and Role

We set out in detail the progress of the project and, by invoking the relevant legal principles and lower-court precedents, emphasized that "justifiable grounds" under Article 178(1)1 of the former Act on Restriction of Special Cases Concerning Local Taxation existed for the plaintiff, as the operator of the senior welfare facility development project, having been unable to directly use the land for a senior welfare facility within the one-year grace period following acquisition. As a result, we successfully demonstrated the illegality of the 안전한 바카라사이트 disposition and obtained a judgment revoking the assessment of a total of KRW 1,894,208,540 in acquisition 안전한 바카라사이트, etc., against our client.

5. Significance of the Judgment

This judgment recognized the existence of "justifiable grounds" under Article 178(1)1 of the Act on Restriction of Special Cases Concerning Local Taxation for a project operator who had made diligent efforts but nevertheless exceeded the grace period. It is expected to serve as a persuasive precedent in future cases where reduced acquisition 안전한 바카라사이트 is recaptured due to the time required for essential administrative procedures in the course of implementing large-scale projects.