해외진출 조세지원제도의 평가와 과제

Abstract

This study analyses the effects of tax incentive programs in Korea for firm’s overseas investment, and suggests some policy recommendations to enhance their incentive effects. First of all, the study deals with the Korean tax system designed to avoid international double taxation for foreign source income. Korean tax law provides the direct foreign tax credit, indirect foreign tax credit and tax sparing to Korean firms that operate and invest overseas. Regarding the direct foreign tax credit system, Korean government’s previous reform effort could receive a positive evaluation in the way that it reduces the excess over the limits of foreign tax credits. However, it seems that the direct foreign tax credit system itself does not have tax incentive effects for promoting Korean firms’ overseas investment, because it neutralizes tax burden between domestic and overseas investment. It is highly appreciated that the tax reform in 2011 has expanded the eligible cases of indirect foreign tax credit system, which provides tax credit for the foreign corporate tax payed at the level of foreign subsidiary. But, the indirect foreign tax credit system could bring a better tax treatment for overseas investment than domestic one, not because of the system itself but because of the incomplete corporate tax system for the dividend income between domestic corporations. Tax sparing system has incentive effect to some extent, for it could guarantee Korean firms tax benefits provided by foreign government. However, it has also limitations in the way that it is applicable only in the case of tax treaty. Based on this analysis this study suggests to introduce a foreign income exemption method to promote firm’s overseas expansion. Meanwhile, this study also proposes to increase tax incentives for developing foreign natural resource and overseas services of firms’ employees.