2. The costs of lawsuit shall be borne by the Plaintiff.

A. On April 2, 2001, the Plaintiff was a domestic corporation established for the purpose of developing electricity resources and producing electricity by physical subdivision from the Korea Electric Power Corporation. Around around 2004 and around 2008, the Plaintiff issued foreign currency bonds overseas for the purpose of raising funds, and paid each interest of KRW 28,019,000 to a foreign corporation which is a bondholder, for the business year 2010, and KRW 22,983,000,000 (hereinafter “interest paid in this case”).

B. The Plaintiff did not submit a payment record under Article 120-2 of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 201; hereinafter the same shall apply) on the premise that the instant interest falls under the domestic source income of a foreign corporation exempt from corporate tax pursuant to Article 21(1)1 of the Restriction of Special Taxation Act (amended by Presidential Decree No. 11133, Dec. 31, 201; hereinafter the same shall apply), Article 120-2 of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22577, Dec. 30, 2010; hereinafter the same shall apply) on the premise that the instant interest falls under the domestic source income of the foreign corporation exempt from corporate tax pursuant to Article 21(1)1 of the former Restriction of Special Taxation Act (amended by Presidential Decree No. 22510, Apr. 21, 2011; hereinafter the same).

다. 그러나 피고는 이 사건 지급이자의 경우 ‘구 조세특례제한법에 따라 비과세면제신청서를 제출하지 아니하는 경우’에 해당하여 지급명세서 제출이 면제되는 대상에 해당하지 않는다는 이유로 2013. 8. 14. 원고에 대하여 2010 사업연도 법인세 100,000,000원(지급명세서 미제출 가산세), 2011 사업연도 법인세 100,000,000원(지급명세서 미제출 가산세)을 각 경정고지(이하 ‘이 사건 처분’이라 한다)하였다. 라.

On November 6, 2013, the Plaintiff appealed to the Tax Tribunal, but was dismissed on March 4, 2014.

【Ground of recognition” has no dispute, Gap Nos. 1, 2, and Eul No. 1 through 5.