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 issued a bond denominated in foreign currency to a domestic corporation that operates securities business, such as trading brokerage, proxy, etc. of securities, with the head office located in Jung-gu, Seoul, Seoul and issued a bond in the foreign currency, and paid the foreign corporation that is the bondholder the interest of KRW 4330 million on July through December 12, 2010 and KRW 792 million on January through December 201, respectively (hereinafter collectively referred to as the “interest paid in this case”).

B. The Plaintiff deemed that the instant interest payment constitutes a domestic source income on which corporate tax is not imposed or exempted under the Restriction of Special Taxation Act, and did not submit a payment record on the instant interest payment pursuant to Article 120-2 of the former Corporate Tax Act (amended by Act No. 11128, Dec. 31, 201; hereinafter “Enforcement Decree”) and Article 162-2(1)1 of the Enforcement Decree.

다. 그러나 피고는 이 사건 지급이자가 조세특례제한법에 따라 비과세면제신청서를 제출하지 아니하는 경우에 해당하여 지급명세서의 제출이 면제되는 대상이 아니라고 보아 법인세법 제76조 제7항에 따라 2013. 7. 9. 원고에 대하여 지급명세서 미제출에 따른 가산세(법인세) 2010 사업연도 귀속분 866만 원, 2011 사업연도 귀속분 1,584만 원을 각 결정고지하였다

(hereinafter collectively referred to as the "disposition of this case"). . [Grounds for recognition] . [In the absence of dispute, Gap evidence Nos. 1, 2, 3, Eul evidence Nos. 1 and 2 (including each number), and the purport of the whole pleadings.

2. The Plaintiff’s assertion of this case is unlawful as follows, and all of the disposition should be revoked.

Article 162-2(1)1 of the Enforcement Decree provides that a statement of payment should be submitted as an exception to the case of “where an application for non-taxation is not filed,” which shall be governed by the Corporate Tax Act or the Restriction of Special Taxation Act.