이전가격제도 변화에 따른 외국인투자기업의 조세회피에 관한 연구

Abstract

The purposes of this study are to examine foreign-invested companies’ degree of tax avoidance using transfer prices after the implementation of the system for preparing and submitting a consolidated report on international transaction related to transfer prices, and to empirically verify whether the system for preparing and submitting a consolidated report on international transaction is effective. The system for preparing and submitting the consolidated report on international transaction has been implemented since 2016. The period for analysis is in this study from 2013 to 2018, i.e., pre-implementation (2013, 2014, 2015) and post-implementation (2016, 2017, and 2018), in order to verify the effectiveness of the implementation of the system. For the sample to be analysed, companies classified as foreign-invested companies were extracted from the KIS-VALUE Ⅱ database, and a total of 1,770 companies comprised of 1,050 manufacturing companies, 582 wholesale and retail businesses, and 138 service industries were selected and then analyzed with SPSS 24.0. This study found that the following results: First, [Hypothesis 1] The degree of tax avoidance will be low after the implementation of the system for preparing and submitting the consolidated report on international transaction. Verification of this hypothesis led to the finding that after implementation of the DBEPS, DIFGR (GM disparity) and DIFO (OM disparity) became higher, while NRGR (GM proximity) became lower; thus it can be concluded that foreign-invested companies have reduced taxable income by lowering the taxable income by manipulating transfer prices using transactions with overseas affiliates. In other words, it was confirmed that the degree of tax avoidance after the implementation of the DBEPS (Consolidated Report on International Transaction Preparation and Submission System) was lower. Second, [Hypothesis 2] After the implementation of the consolidated report on international transaction preparation and submission system, the degree of tax avoidance of companies with many related transactions with overseas affiliates would be low. Verification of this hypothesis led to the finding that RSALERATIO (overseas affiliate sales transaction ratio) showed a significant positive (+) effect on the dependent variable DIFO (OM disparity). This shows that the use of transfer pricing manipulation has decreased. However, it was found that the implementation of the system did not have a significant effect on DIFGR (GM separation), DIFO (OM separation), and NRGR (GM proximity). This study is an empirical analysis of how foreign-invested companies' tax avoidance behavior through various methods using transfer prices changes after the implementation of the consolidated report on international transaction preparation and submission system. It is expected that the results of the study verifying the taxation authority will have implications for Korean tax authorities’ securing tax sources and establishing policies.