마일리지 관련 거래와 부가가치세

Mileage is widely accepted to increase sales and secure customers continuously, and the issue on the matters of taxation is under active discussion. The purposes of this article are to contemplate how supply value of VAT is calculated in the transactions relating to mileage and to clarify problems of legislation and construction, subsequently providing alternatives for the problems. Another key issue is whether taxation on mileage can remain neutral against other transactions that aim to stimulate sales like business gifts. A regulation was written saying, “if goods are supplied and the goods are compensated in the entirety or in part through accumulated mileage, the value of the mileage used to compensate for the goods supplied shall be included in supply value.” And the construction based on this regulation is under progress. However, if the mileage does not have the nature of compensation, its value cannot be included in supply value. Mileage that does not function as compensation should be excluded from supply value, regardless of the form of rewards or the identities of the party banking the mileage and the party providing the rewards. Above regulation would lead to the result which stands in contrast to the fundamental principle of VAT. When interpreted in this way, neutrality of taxation on taxable business gifts could come into question. However this conforms to legislative selection. Moreover, the above regulation covers only a narrow range of transactions involving mileage, while there are no regulation for cases in which the business managing the accumulation of mileage is not the same business providing the rewards of the mileage, or in which the rewards come in the form of service instead of goods. The regulation is applied only when mileage has the nature of compensation. There needs to be legislative improvements, such as repeal or limitation of scope on regulation.