• Environmental and Resource Economics Review
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• v.31 no.4
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• pp.711-731
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• 2022

In Korea, nuclear power plants are major sources of electricity supply with relatively low costs. Despite the importance and scale of nuclear electricity generation, the Korean tax and levy system is less organized than those in other countries, such as France and Japan, where nuclear power plants also play significant roles for electricity supply. Countries impose tax on nuclear electricity generation roughly in three ways: tax on nuclear reactors; tax on uranium fuel; tax on electricity from nuclear power plants. The Korean government may consider taxing nuclear electricity generation based on uranium fuel or electricity generation. If taxing on uranium fuel at the rate of 90 KRW per milligram of uranium, the Korean government can collect additional tax revenue of 430 billion KRW. If taxing on electricity from nuclear power plants at the rate of 11 KRW per kilowatt-hour, the government can collect additional tax revenue of 1,600 billion KRW.

• The Korean Journal of Financial Studies
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• v.1 no.2
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• pp.257-280
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• 1994

합병의 절세효과는 배당소득의 자본이득화, 소유구조강화의 비용철강, 합병교부주식의 액면가액과시장가치의 차이에 의한 배당소득세의 회피 가능성 등으로 발생한다. 그러나 합병에 청산소득법인세, 사업년도법인세 및 증여세 등의 증세효과도 존재한다. 순절세효과는 당해 회사의 조세상 특성에 따라 달라진다. 합병회사가 피합병회사의 이월결손금과 조세공제.감면혜택을 승계받을 수 없다. 조세적 특성의 승계단절을 우회하기 위하여 신설합병보다는 흡수합병의 형태가, 순합병보다는 역합병의 방식이 선호된다. 합병에서 임의평가증(任意評價增)의 세금효과는 여러 가지 요소에 의하여 결정되는 데. 순절세효과가 양,수일 경우는 흔치 않을 것이다. 합병비율의 조절을 통하여 소유구조변경과 증여효과를 얻을 수 있다. 합병비율조절의 유인은 증여세, 청산법인세 및 배당소득세 등의 증세효과와 원천징수의무에 의하여 감소한다. 특히, 청산법인세와 배당소득세는 실행합병비율이 1:1이 되도록 하는 요인이다. 증여유인과 증세효과로 주주집단간의 이해관계대립이 초래될 수 있다 이해갈등의 예방장치 또는 조정제도의 효율성은 실행합병비율과 공정합병비율의 괴리를 축소하는 요인이 될 것이다.

• Management & Information Systems Review
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• v.35 no.2
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• pp.67-81
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• 2016

The purpose of this study was to investigate lots of problems that the current tax appeal system has, which are becoming serious issues as tax appeal cases are recently increasing. Those problems include the unreasonable procedure and period of deliberation on tax appeal cases, permission of a same tax appeal by more than one governmental agencies and the compulsory transposition system of tax appeal cases. All of these problems should be rectified in order to ensure that the currently tax appeal system protect taxpayers' rights and interests effectively. According to the current tax appeal system, the period from the receipt of tax appeal cases to ruling on them is up to 90 days. This is unrealistic, so that period should be allowed to be extended if those cases about more complicated taxation or if they are even harder to be treated for any reason. At present, chief of Tax Tribunal has to unconditionally accept resolution from the meeting of tax judges and make a ruling accordingly because he has no right to reject that resolution. But now, it's time to establish legal grounds based on which the chief suggests the tax judges to reconsider their resolution if it is undoubtedly wrong. Currently, there's a relatively little acceptance of tax appeals from people who can't financially afford to designate a proxy for them. To solve this problem, lots of efforts to make socially recognized the necessity to relive those people's rights and interests and make widely known the Public Proxy of Tax Appeal System. The current tax appeal system allows the Board of Audit and Inspection to be an appealer. This means taxation may be deliberated on by more than one governmental agencies. It is so inefficient. Therefore, tax appeal by the board should be only about taxation that they found unacceptable by audit and inspection. Except for this, it is not allowed that the Board of Audit and Inspection file tax appeals that are, in turn, necessarily transported to the National Taxation. Esecially, the transposition should be a procedure that is occasionally taken. In sum, this study investigated problems with the current tax appeal system, and made suggestions about solutions that are not theoretical but practical.

• Proceedings of the Technology Innovation Conference
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• 1998.06a
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• pp.180-207
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• 1998

본 논문에서는 국내 제조업 기업을 대상으로 한 $\ulcorner$기술혁신조사$\lrcorner$ 통계를 바탕으로 기업의 혁신 활동과 이를 지원하고 있는 각종 정부지원제도에 대한 실효성을 다루었다. 분석대상 기업의 수는 2,591개였고, 기술혁신지원 프로그램은 11개로 조세지원제도가 7개 기술지원제도가 6개였다. 기술혁신지원 프로그램의 실효성을 분석하는 실증모형에는 선택변수모형이 이용되었으며, 실증결과는 현재 시행중인 분석대상 기술혁신지원제도의 실효성이 실망스러운 것으로 나타났다. 이들 프로그램의 효과는 대체로 10% 미만이었고, 대기업과 중소기업에 대한 적절한 차등효과를 가져오지 못하는 것으로 판단되었다. 이에 따라 기술혁신지원제도에 대한 개선이 보다 현실성 있게 개선되어야 할 것으로 보인다.

• Journal of Technology Innovation
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• v.17 no.1
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• pp.1-48
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• 2009

Recently we have found some symptoms that R&D fiscal incentives might not work well what it has intended through the analysis of current statistics of firm's R&D data. Firstly, we found that the growth rate of R&D investment in private sector during the recent decade has been slowdown. The average of growth rate (real value) of R&D investment is 7.1% from 1998 to 2005, while it was 13.9% from 1980 to 1997. Secondly, the relative share of R&D investment of SME has been decreased to 21%('05) from 29%('01), even though the tax credit for SME has been more beneficial than large size firm, Thirdly, The R&D expenditure of large size firms (besides 3 leading firms) has not been increased since late of 1990s. We need to find some evidence whether fiscal incentives are effective in increasing firm's R&D investment. To analyse econometric model we use firm level unbalanced panel data for 4 years (from 2002 to 2005) derived from MOST database compiled from the annual survey, "Report on the Survey of Research and Development in Science and Technology". Also we use fixed effect model (Hausman test results accept fixed effect model with 1% of significant level) and estimate the model for all firms, large firms and SME respectively. We have following results from the analysis of econometric model. For large firm: i ) R&D investment responds elastically (1.20) to sales volume. ii) government R&D subsidy induces R&D investment (0.03) not so effectively. iii) Tax price elasticity is almost unity (-0.99). iv) For large firm tax incentive is more effective than R&D subsidy For SME: i ) Sales volume increase R&D investment of SME (0.043) not so effectively. ii ) government R&D subsidy is crowding out R&D investment of SME not seriously (-0.0079) iii) Tax price elasticity is very inelastic (-0.054) To compare with other studies, Koga(2003) has a similar result of tax price elasticity for Japanese firm (-1.0036), Hall((l992) has a unit tax price elasticity, Bloom et al. (2002) has $-0.354{\sim}-0.124$ in the short run. From the results of our analysis we recommend that government R&D subsidy has to focus on such an areas like basic research and public sector (defense, energy, health etc.) not overlapped private R&D sector. For SME government has to focus on establishing R&D infrastructure. To promote tax incentive policy, we need to strengthen the tax incentive scheme for large size firm's R&D investment. We recommend tax credit for large size film be extended to total volume of R&D investment.

• Korean Business Review
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• v.15
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• pp.59-78
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• 2002

It is only 9 to 10 years since the use of internet became commercial. But electronic commerce is now a familiar form of commercial transaction. Though the ratio of electronic commerce compared to total commercial transaction is still low, it is certain that electronic commerce will be the major form of transactions in the future. In July 1, 1997, United States made a public "A Framework for Global Electronic Commerce" to set up Internet to be a duty free zone and declared to play the trigger role in getting the international discussion of "A Framework for Global Electronic Commerce". In July 8, 1997, EU also adopted "Bonn Declaration"-minimizing government regulations and imposing no new tax on electronic commerce. Focusing the international trend, we need to develop the tax policy that is suitable for our country situation as soon as we can. To be able to do that, we must make an endless effort like selecting professionals, making new administrative part and supporting the research.

• The Journal of Small Business Innovation
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• v.20 no.1
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• pp.1-18
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• 2017

This study examined whether divided and spun-off companies design and execute spin-offs to minimize tax burdens by analyzing multiple spin-off transactions in the Dongbu Group, when the Korean tax law regarding corporate restructuring was amended in July 2010. Before the July 2010 tax amendment, taxes on the capital gains arising from the qualifying spin-off were deferred to the earlier of the shares in or assets acquired by the spun-off company are disposed. This tax treatment relieves the divided company's tax burden by deferring taxes on capital gains, compared with non-qualifying spin-offs. However, if shares in or assets acquired by the spun-off company are disposed after the July 2010 tax amendment, the capital gain incurred at the time of the qualifying spin-off would be taxed again at the spun-off company, in addition to a taxation on the divided company's capital gains. This creates double taxation implications for the parties involved in the spin-off. As a result, the double taxation may outweigh the benefit from the tax deferral on the qualifying spin-off, which may make a qualifying spin-off tax unfavorable. Among the four spin-off cases in the Dongbu Group addressed in this study, a spin-off occurred before the tax amendment, whereas three spin-offs occurred after the tax amendment. Initially, we expected that the spin-off before the tax amendment would be a qualifying spin-off, and the other three spin-offs would be non-qualifying spin-offs, considering the taxation rules before and after the July 2010 tax amendment. However, based on the review of summarized balance sheets disclosed in the spin-offs' corporate filings, no capital gains arose during the four spin-offs that occurred in the Dongbu Group. Therefore, we concluded that the Dongbu Group considered non-tax factors more than tax factors while designing and executing the spin-offs. The local media posited during this period that these spin-offs may intend to resolve financial issues in the Dongbu Group, and this analysis was supported by the fact that some shares in the new spun-off companies were sold by the Dongbu Group. Our case studies provide evidence that all costs, including both tax and non-tax costs, must be considered in the course of spin-offs, in addition to the tax burdens on all parties involved in the corporate restructuring, which parallels the work of Scholes et al. (2008). This study provides implications that various aspects should be considered and reviewed in advance when the management makes decisions for effective tax planning.

• 주택과사람들
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• s.187
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• pp.34-35
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• 2005

개발이익의 환수는 부담금을 늘리는 것보다 기존 조세 제도를 제대로 운영하면 충분히 그 효과를 살릴 수 있다는 지적도 나온다. 이미 땅값이나 집값 상승에 대해서는 양도소득세를 통해 이익의 일부를 세금으로 거둬들이고 있다. 개발사업으로 이익을 본 기업도 법인세를 내고 있다. 따라서 기족 세법 테두리에서 개발이익에 대한 철저한 환수를 할 수 있도록 보완책을 마련하는 게 정도(正道)라는 지적이다

• Journal of Labour Economics
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• v.37 no.4
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• pp.89-112
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• 2014

This paper characterizes an optimal combination of grant and income-contingent loans (ICL) from efficiency and equity points of view as a government subsidy program for higher-education. In particular, we show that it is always desirable to introduce ICL for students regardless of their household incomes, and also provide arguments for the superiority of tax-financing system to loans with risk-premium as a financing mechanism of ICL. From policy point of view, this paper suggests a need for the extended coverage of our ICL system, while justifying its current tax-financing system.

• Korean Business Review
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• v.11
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• pp.319-341
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• 1998

Transfer pricing is a process for determining the prices of products, technology and services among affiliated companies. Although taxation problems arising from international investment are not now, they have become more important in recent years as a consequence of the growing internationalization of economic activities. So, trans pricing to shift their income and expenses from one country to another has made it difficult for tax administrations to impose tax collectly. Our government also applies arm' length methods to decide equitable tax. In the case of intangibles, because of the characteristics of the market, it is not easy to find the comparable uncontrolled transactions and it is almost impossible to apply cost=plus method or resale price method. This paper treats these problem, examining U.S. regulations and OECD guidelines and analysing the practice of transactions and the application of other methods.