기업 상속 관련 세제의 국제비교와 한국의 제도개선에 대한 시사점

Recently, many countries try to introduce inheritance tax relief for business succession. In 2007, Korean government expanded inheritance tax relief for business succession of small and medium enterprises. Regardless of this expansion of tax relief, there are strong debates on the inheritance tax relief for business succession in Korea. This study compares the inheritance tax for business succession in Germany, Japan, Korea, UK and the U.S. The differences of inheritance tax for business succession among five countries could provide useful clues for the future inheritance tax reform in Korea. According to the results of this study, Korean inheritance tax system is not favorable for business succession in general. Especially, the Korean inheritance tax law has a provision of value increase for the controlling shares of the inherited company. This special rule leads to a higher inheritance tax burden for business succession in Korea. Moreover, the value increase rate for large companies is two times higher than the case of small and medium companies. That kind of rule cannot be found in other four countries of this study. Since the inheritance tax reform 2007 in Korea applies only to small and medium companies, even though the value increase for controlling share also applies to SMEs, there is no chance for any relief of inheritance tax burden in case of business succession of large companies. Instead of inheritance tax relief, the business succession of large Korean companies bears additional tax burdens due to the value increase for controlling shares. Regarding the future inheritance tax reform in Korea, most of all, the unfair inheritance tax treatment for business succession of large companies should be abolished. Moreover, inheritance tax relief for business succession should be applied equally to all companies regardless of the firm sizes.