이원화된 부동산 보유세 경정청구제도의 괴리：종합부동산세 경정청구 개정을 배경으로

Abstract

[Purpose]The purpose of this study is to review and seek solutions to the issues and improvement plans for the dualized real estate holding tax system in Korea, in the context of the revised request for correction system for the comprehensive real estate tax, which has been applied since 2023 (extending the period for requesting correction of the comprehensive real estate tax issued by notification). Although the comprehensive real estate tax is principally a government－imposed tax, taxpayers can choose to file and pay it themselves, leading to discrepancies in the request for correction deadlines depending on the taxpayer’s choice. In 2022, the Basic National Tax Act was revised to extend the request for correction deadline for the notified comprehensive real estate tax to five years from the payment deadline. [Methodology]This study reviews the domestic system and compares it with foreign systems, focusing on whether they have a dualized real estate holding tax system. Additionally, it analyzes the cases of Company A and Company B related to the request for correction of real estate holding taxes to draw implications and identify issues and improvement plans for the current system. [Findings]Cases where real estate holding taxes are dualized at both the local and central government levels, like in Korea, are rare compared to foreign examples. Thus, the inconsistency in the request for correction periods for national and local taxes in Korea is likely to cause significant confusion for taxpayers. Additionally, in countries with dualized systems, the central and local governments tax different subjects, so issues arising from the linkage between holding taxes (property tax and comprehensive real estate tax) as seen in Korea do not occur. The cases of Company A and Company B also showed that taxpayers face unexpected tax burdens due to the linkage between holding taxes, and flaws in the property tax system, a preceding holding tax, affect the subsequent comprehensive real estate tax, resulting in missed opportunities for requesting corrections. [Implications]Based on the analysis of foreign systems and domestic cases, this study suggests the following implications. First, it is necessary to extend the request for correction period for the current property tax to five years, similar to the revised comprehensive real estate tax. Second, it is necessary to consider unifying the currently dualized real estate holding taxes, and this should be done neutrally to ensure that there is no change in the current tax revenue.