연구인력개발비 세액공제 대상 위탁연구개발비에 관한 연구

Abstract

[Purpose]In relation to tax credit for R&D expenditures, this study analyzed the trend of precedents focusing on consigned R&D expenses subject to tax credit, which is one of the reasons for litigations between taxpayers and tax authorities. [Methodology]For the analysis, precedents related to tax credit for R&D expenditures were collected from the National Tax Law Information System. Among the collected precedents, those related to consigned R&D expenses were classified by major topics to derive implications. [Findings]The trends of precedents related to the major topics are as follows. First, ERP system do not fall under the R&D expenses subject to tax credit. Second, re－consignment costs for R&D were recognized as expenses subject to tax credit in the same way as consignment costs even before regulations related to the re－consignment were amended. Third, after the revision of the enforcement ordinance, tax credits were recognized only for the parts directly performed by the dedicated department of the entrusted company. [Implications]This study attempted to resolve issues related to consigned R&D costs that have not been largely addressed in previous studies.