상속세법상 보충적평가방법의 순손익가치와 순자산가치 가중치의 적정성 분석

The purpose of this study is to examine the appropriateness of the weights(3:2) of net income value(NIV) and net asset value(NAV) in the complementary valuation method under the Inheritance and Gift Tax Law (‘tax valuation method’ hereinafter). We reviewed the theoretical background related to this study, the characteristics and problems in the tax valuation method, the valuation methods in major foreign countries and the results of previous researches by the literature review, and performed the empirical analysis using financial data and MSP data of companies listed on KSE or KOSDAQ. This study applied the regression analysis method. Tax valuation method must guarantee the legislative fairness of tax duties. This study tested the MSP explanation of tax valuation method and the adequacy of the weights(3:2) of NIV and NAV through 9,658 companies listed on KSE and KOSDAQ during 9 years from 1998 to 2006. The results of study are as follows ;First, according to the results of regression analysis on the MSP explanation of NIV and NAV ; 1) In listed shares on KSE, the MSP explanation of NIV and NAV were 0.24 and 0.48. This means that NAV is higher MSP explanation ability 2) In listed shares on KOSDAQ, the MSP explanation of NIV and NAV were 0.59 and 0.17, so NIV showed higher MSP explanation ability. Thus, the results of analysis on MSP explanation were different between shares listed on KSE or KOSDAQ. Second, when the MSP explanation of NIV and NAV were analyzed considering the yearly stock price index and company characteristics, the regression coefficients of each variable appeared different according to yearly stock price index․company size and ․business category. This suggests empirically that the tax valuation method, which applies the weights(3:2) of NIV and NAV uniformly regardless of the type of listing․yearly stock price index․size and business category, hinders the fair valuation of unlisted stocks. These results validate that the tax valuation method weighted averages of NIV and NAV is inadequate theoretically and unacceptable the legislative fairness of tax duties. The tax valuation method should be improved in a new methods reflecting stock price index․business category and size. In addition, the average valuation price for 2 months before and after the closing date was almost the same as that for 1 month before and after the closing date. Therefore it appeared unuseful that prescribed differently in Inheritance Tax Law and Income Tax Law.