1. All of the plaintiff's claims are dismissed.

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

1. Details of the disposition;

A. The Plaintiff is a domestic corporation established with the aim of promoting the reasonable operation of housing construction, supply, lease and management under the Korea Land and Housing Corporation, the Housing Act, etc.

B. The Plaintiff issued overseas bonds denominated in foreign currency, and paid each interest on the bonds to a foreign corporation, the bondholder of which is a foreign corporation, through Deutche Bank, KRW 43,341,546,840, KRW 75,119,528,978, KRW 79,400,910,100, and KRW 105,000,000 for the year 2012 (hereinafter “interest paid”).

Article 120-2 of the former Corporate Tax Act (amended by Act No. 11128, Dec. 31, 201; hereinafter “Corporate Tax Act”) and Article 162-2(1)1 of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 24357, Feb. 15, 2013; hereinafter “Enforcement Decree”) deeming that the instant interest paid constituted a domestic source income on which corporate tax was not imposed or exempted under the Restriction of Special Taxation Act, the Plaintiff did not submit a statement of payment concerning the instant interest paid pursuant to Article 120-2 of the former Corporate Tax Act.

다. 피고는 2013. 12. 18. 원고에게 이 사건 지급이자가 조세특례제한법에 따라 비과세면제신청서를 제출하지 아니하는 경우에 해당하여 지급명세서의 제출이 면제되는 대상에 해당하지 않는다는 이유로 법인세법 제76조 제7항에 따라 지급명세서 미제출에 따른 가산세(법인세) 2010 사업연도 귀속분 100,000,000원, 2011 사업연도 귀속분 100,000,000원, 2012 사업연도 귀속분 100,000,000원을 각 결정고지하였다

(hereinafter collectively referred to as “instant disposition”). D.

The Plaintiff appealed and filed an appeal with the Tax Tribunal on March 14, 2014, but the claim was dismissed on May 26, 2014.

[Ground for Recognition: Facts without dispute, Gap evidence 1, 2, 3, Eul evidence 1, the purport of the whole pleadings]

2. The Plaintiff’s instant disposition is as follows.