공익법인의 세금 유인에 의한 원가이전 현상 ― 사회복지법인을 중심으로 ―

Prior studies have been focusing on taxation system of non-for-profit organizations, through tax law perspective. In that point, our paper is the first step study to try to study empirically these organizations, using the disclosed financial statements. There is the differential taxation about non-for-profit organizations that have tax-exempt for business income and taxable for unrelated to business income, respectively. This setting is seems to be Sholes and Wolfson(1992)'s one that is type of strategies by means of shifting income from one pocket to another. In short, Expenses in the tax-exempt department is shifted into deductible expenses. This paper investigates behaviors of non-for-profit organizations that engage both business income and unrelated to business income department whether they shift costs(expenses) from tax-exempt department into taxable department, using from FY2008 to FY2009, Korean social welfare corporations(including entire 130 organization-years). Cost-shifting phenomenon can be measured by the following Yetman(2001) and Hofmann(2007)'s process. First, estimated cost of unrelated to business income department is estimated by using estimated cost model and then,it compared to actual cost that is reported by disclosure system of IRS. If differences between estimated and actual cost is negative, Cost-shifting called by prior papers occurs. Results of this paper indicate that non-for-profit organizations shift costs from tax-exempt department into taxable department in order to decrease tax-burden as increase deductible expenses of taxable department. And also this paper show that amount of the shifted cost is about 0.9billion won per organization and reduced tax is about 0.2 billion won per organization. Contributions of this paper are to suggest that it is extension of empirical paper to the taxation of non-for-profit organizations and several empirical evidences to authorities considering taxation of profit-making medical corporations.