지입제의 과세문제에 관한 연구

So-called Jeeipje is a unique working system that someone has real ownership for his car, but gives legal ownership for his car to freight transportation company. Jeeipje brings about a lot of taxation issues because of inconsistency of external ownership and internal control. This article explores taxation issues related to Jeeipje. First, the Article 7 (10) of the Local Tax Act stipulates that a car owner should pay acquisition tax when a freight transportation company acquires a car with a mandate from a car owner. However, this stipulation deviates from Supreme Court's Precedents which regards a nominal person as a tax payment obligor of acquisition tax. Second, a car owner makes registration of entrepreneur and runs a car independently of freight transportation company. Therefore, income from a car service becomes vested in a car owner according to substance over form doctrine by the Article 14 of the Framework Act of National Tax. Last, when a transportation company acquires a car with a mandate from a car owner, the seller of the car should issue a tax invoice to the transportation company, and the freight transportation company should issue a tax invoice to the car owner. When a car owner runs a car, a car owner should issue a tax invoice to the customer because income from a car service becomes vested in a car owner.