국내 전환사채의 회계 및 과세제도 비교연구

Abstract

The purpose of this study is that compare the recognition method of interest expenses(profit) on tax and accounting of convertible bond which is the typical equity-linked bond, so suggest the improvement plan of taxation of convertible bond. For this purpose, after check multilaterally the convertible bond accounting method and taxation system on not only issuing company but also investor situation and based on these points, try to suggest the appropriateness and problem of convertible bond interest expenses and interest income taxation system. Nevertheless, the economic essence of conversion right adjustment of convertible bond is basically same with straight bond's discount of straight bond, because that is not recognized as interest expenseon tax or deferred recognized late on tax, there is a disadvantage that the corporate tax shield of the issuing company decreases. Also, when investor converts the stock on tax, there are not only problem of unrealized income taxation but also bundling effect according to interest income taxation on redemption premium of convertible bond. To improve these, there is necessity that mitigates the taxation distinction as follow stock type of issuing company by applying accrual method to the interest expenses recognition method and time of convertible bond on tax same with straight bond. In additionto these, there are necessities that apply cash based method to redemption premium for the prevention of unrealized income taxation, meanwhile should apply separate taxation to that for the mitigation of bundling effect. On mid-long term, there is necessity that makes a taxation principle which improve the taxation equity between the equity-linked bonds as the bond with warrants etc. which have similar nature with convertible bond also. And we expect that this study will contribute to the preparation of consistent and rational taxation system through this study for hybrid securities which comes to be more various little by little and complicated.