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 company established on December 29, 1998 and engaged in the business of manufacturing glass processing, etc. in Yongcheon-si B.

The Plaintiff reported each corporate tax for the business year from 2010 to 2015 and calculated the interest rate on the provisional payment paid to C, who is its representative director, pursuant to Article 89(3)2 of the Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22577, Dec. 30, 2010; hereinafter the same shall apply) as the market price pursuant to Article 89(3)2 of the Enforcement Decree of the Corporate Tax Act (hereinafter “applicable interest rate”) as follows:

In the business year 2010, 2012, 2011, weighted average interest rate of overdrafted loan interest rate in the interest rate applied in 2015 in 2014, 2014 / [the table] applicable interest rate choice status of applicable interest rate

B. On June 5, 2017, the Director of the Daegu Regional Tax Office issued a comprehensive audit on the Defendant from June 5, 2017 to December 23, 2017, and notified the Defendant that the recognition of the Plaintiff’s business year 2014 and 2015 was calculated as follows.

According to Article 89 (3) 2 of the Enforcement Decree of the Corporate Tax Act, where the interest rate on the overdraft is selected as the market price, the interest rate on the overdraft loan is selected as the market price and the next two business years are the market price.

Although the Plaintiff selected the interest rate on the current loan at the market price in the business year 2013, the Plaintiff calculated the interest rate on the provisional payment by applying the weighted average loan interest rate to the two business years thereafter.

C. Accordingly, on September 7, 2017, the Defendant re-calculated the interest rate recognized as the market price by applying the interest rate on the temporary payments in the business year 2014 and 2015 to the Plaintiff. Based on this, the Defendant issued a revised notification of KRW 6,679,520 of corporate tax belonging to the business year 2014, and KRW 9,010,80 of corporate tax belonging to the business year 2015, respectively.

(hereinafter “instant disposition”) D.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on December 4, 2017, but on March 6, 2018.