수입배당금 익금불산입 제도의 문제점 및 개선방안

Abstract

Despite the enforcement of dividend received deduction(“DRD” hereafter), dual taxation problem on corporate shareholders can’t be conceptually solved perfectly. Such imperfect feature comes from the fact that the ratio of DRD is not as high as needed. The results of this study shows that, besides de-facto dual taxation on individual shareholders, imperfect DRD works to aggravates economic burden of those shareholders in the final stage. Although DRD gives rise to considerable tax saving effect, aforementioned imperfect feature triggers 5.9% of tax burden in the corporate stage on average, which further increases the effective tax rate in the corporate stage from 27.6% to 32.1%, and increases the overall effective tax rate in the final stage from 39.6% to 43.4%. Increased tax burden of individual shareholders in the final stage caused by circuitous payment of dividends to individual shareholders, not direct payment, is because of the DRD’s effect on imperfect clearance of dual taxation and increased effective tax rate in the corporate stage. Thus, the DRD ratio needs to be raised to lower the 5.9% of additional tax burden in the corporate stage. Summing up, the insufficient level of DRD on circuitous payment of dividends, as well as the imperfect clearance of dual taxation in the final stage, substantial tax burden accrues supplementarily. Thus, such disadvantageous additional tax burden should be relieved through the downward adjustment of existing DRD ratio.