1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff issued a foreign currency bond in a foreign country to a domestic corporation established for the purpose of developing electric resources, etc., and thereafter paid 20,092,442,400 won as interest to the foreign corporation holding the bonds in the business year 2010, 33,741, 325,50 won in the business year 201, and 30,463,685,200 won as interest for the business year 2012 (hereinafter “interest for the instant case”).

B. The Plaintiff did not submit a statement of payment pursuant to Article 120-2 of the Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010; hereinafter the same shall apply) and Article 162-2(1)1 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 ground that the interest paid in the instant case constitutes a domestic source income exempt from corporate tax pursuant to Article 21(1)1 of the Restriction of Special Taxation Act on the grounds that it constitutes a domestic source income exempt from corporate tax pursuant to Article 21(1)1 of the Restriction of Special Taxation Act.

다. 그러나 피고는 이 사건 지급이자의 경우 조세특례제한법에 따라 비과세면제신청서를 제출하지 아니하는 경우에 해당하여 지급명세서 제출이 면제되는 대상에 해당하지 않는다는 이유로 2013. 8. 8. 원고에 대하여 2010 사업연도 법인세 100,000,000원(지급명세서 미제출 가산세), 2011 사업연도 법인세 100,000,000원(지급명세서 미제출 가산세), 2012 사업연도 법인세 100,000,000원(지급명세서 미제출 가산세)을 각 경정고지(이하 ‘이 사건 처분’이라 한다)하였다. 라.

On November 7, 2013, the Plaintiff appealed to the Tax Tribunal, but the said claim was dismissed on March 17, 2014.

【Ground of recognition】 The fact that there has been no dispute, entry of Gap's 1 through 3 (including family identifications) and the purport of whole pleading

2. Whether the instant disposition is lawful

A. The plaintiff's assertion (1) Article 162-2 of the former Enforcement Decree of the Corporate Tax Act.