K-IFRS 도입에 따른 연결납세제도의 효과적 운영방안

Although consolidate tax return, which allows business groups to return their corporate income taxes based on consolidated taxable income, has been enforced since 2010, complicated features make most taxpayers have difficulty in understanding and coping with that system. Furthermore, International Financial Reporting Standards (IFRS) forces all listed firms to prepare consolidated financial statements, which adds greatly to accountants and financial market participants’ confusion of accounting and tax practice. Based on recognition of this problem, this study suggests practical plans to revise tax laws to effectively implement consolidated tax return in accordance with the adoption of IFRS consolidated financial statements. First, IFRS has not yet prescribed the scope of accounting disclosures of business groups to reflect the adoption of consolidated tax return and, as a result, each IFRS-adopter decides the disclosures at its own discretion. To help stakeholders of each firm in business groups make efficient investment and financing decisions, the effects of consolidated tax return on each firm’s tax liabilities and net operating losses should be disclosed clearly. Second, although the accounting principles of listed firms are quitely different from those of non-listed firms and, as a result, losses of separate firms have different features from each other, IFRS treats both losses equally. To prevent both losses from being evaluated equally for tax reporting, consolidated tax return should prescribe that losses of listed (non-listed) firms of business groups are not allowed to compensate for the taxable incomes of non-listed (listed) firms of same business groups. Finally, corporate income tax law itself should also be revised to accord with the adoption of IFRS as follows. (1) IFRS’s strict requirements for recognition of allowance for bad debts could cause the taxable income of IFRS-adopters to greatly increase and, as a result, obstruct smooth settlement of IFRS and consolidated tax return. So, enough tax preferences for such firms should be included in corporate income tax law. (2) The accounting treatment of loans to employees is not line with the tax treatment of them and, as a result, the constructive interest income of those loans are inadequately added to taxable income. So, such interest income should be exempt from taxable income calculation, or opposite tax adjustement should be allowed when such loans are retrieved. (3) IFRS’s strict criterion for the disposition of financial assets could contradict the recognition criteria of tax law and, as a result, lead to massive burden of tax adjustment for IFRS-adopters. So, corporate tax law should allow IFRS-adopters’ recognition criteria for the disposition of financial assets to comply with the criteria which IFRS stipulates.