Supreme Court dismissed appeal; late disclosure of foreign capital status precludes late payment interest under tax debt law.

The Supreme Court dismissed the cassation appeal against a lower court ruling that denied late payment interest to a social insurance fund. The appellant, a company, only disclosed its status as a foreign capital enterprise in a revision letter months after the relevant tax decisions were issued. The court held that late payment interest under the Tax Debt Act requires a decision change caused by an error, which was not the case here since the delay was due to the appellant's own failure to inform the authority.