마일리지 결제 시 부가가치세법상 매출에누리의 인정 여부

Value Added Tax Act implementing ordinances article 61 ④ regulate mileages which are accumulate for first supply of goods and services and used for next supply of goods and services by customers are included in tax base. Some lawyers insist that this article causes problems of double taxation about VAT of mileages which is levied in first supply. So cases which assert mileages should be deducted from first supply's tax base or second supply's tax base are on in the court. In this paper, we can see in case of mileage payment, VAT of mileages are also paid by mileages and if mileages are deducted from first or second tax base then over collection of VAT is caused. This is the result of the feature of mileages which are used only the way of payment when customers who accumulate mileages use those mileages in the second supply's way of payment. Mileages have the characteristics of rewards after the first supply. Mileages are not discount so they should not be deducted from first or second tax base. Mileages are rewards only when customer uses them in second supply.