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. Under the Korea Electric Power Corporation Act, the Plaintiff issued bonds in foreign currency to a domestic corporation established for the purpose of promoting the stability of electricity supply and demand by promoting the development of electric power resources and operating the electric utility business in a reasonable manner, and paid each interest of KRW 163,34,467,718 (hereinafter collectively referred to as “interest paid in this case”) to a foreign corporation which is a bondholder, from July to December 2010.

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. 8. 8. 원고에 대하여 지급명세서 미제출에 따른 가산세(법인세) 2010 사업연도 귀속분 1억 원, 2011 사업연도 귀속분 1억 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, and 3, Eul evidence No. 1 (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 "where an application for non-taxation is not filed, a statement of payment shall be submitted as an exception to the exception, which shall be either the Corporate Tax Act or the same.