투자지국의 배당소득 익금불산입제도 신설이 원천지국 자회사의 배당성향 및 이익률에 미치는 영향 - 일본계 기업을 중심으로

This paper examines the effect of tax reform of Japan, which received dividends from foreign subsidiary is 95%-exempt from 2009, on Japanese subsidiary in Korea. Japan abolished in 2009 the foreign tax credit related to dividends from foreign subsidiaries to the parent company in Japan. Instead, Japan adopted the foreign dividend exemption method and the dividend from foreign subsidiaries became non-taxable income. Due to the higher corporate income tax rate in Japan, it has been more preferable to retain the profits of foreign subsidiary locally than to pay dividends to Japanese parent company. Japan authorities expect to stimulate the Japanese economy by adopting the foreign dividend exemption method. Because of in the exemption method, the tax burden of dividends from foreign subsidiaries is reduced and many Japanese firms don't need to retain locally or hesitate to send their retained earnings to Japan. Corporate income tax rate in Korea is lower than that of Japan and it may be an effects of the foreign dividend exemption method on the tax strategy of Japanese subsidiary. Chi and Choi (2013) investigated this tax reform by case study method. They suggested three types of possible tax strategy of Japanese subsidy. The first type is to delay that date of dividend payment to the enforcement date of the exemption method. The second type is to change from royalties to dividends, because the foreign dividend exemption method may sufficiently increase preference to dividends among the methods of sending foreign subsidiary’s profits to the parent company. The last third type is to increase profits to foreign subsidiaries using transfer pricing for switching the place of profit attribution. We investigate the effect of Japanese tax reform on income ratio and dividend tendency of Japanese subsidiary in Korea, which are deflated by prior total asset and total sales, and deflated by net income and prior total asset, respectively. For this study, we hand-collect consecutive active company in Korea from 2008 to 2011, for, most subsidiaries are unlisted companies. Specifically, this research investigates three subjects. The first research question is how much Japanese subsidiary in Korea increase its payment dividends and the increased dividends are real or tax-strategic. We analyze the dividends payment of each year from 2008 to 2011 and find that the dividend payment of 2009, just before the exemption, is reduced and that of 2010 is increased significantly. This result explains that the deferral dividend strategy is utilized for saving tax payment in Japan. The second research question is whether net income increases abnormally from transfer pricing or economical support for switching the place of profit attribution. In this case, to prove abnormality needs the matching samples which are assumed normal. For this reason, we collect matching samples and use to investigate the second and the third research questions. Japanese subsidiaries are more profitable after tax reform than before tax reform and the rate of profit is abnormally increased than that of normal matching firms. The third research question is whether there is no effect on dividend tendency in result of tax strategy. If dividend tendency after tax reform is really increased, Japanese authorities may achieve their policy purposes, if not, Japanese subsidiaries just use the policy and Japanese authorities may fail their policy purposes. We find that there is no insignificant difference of dividend tendency between after and before tax reform, and between Japanese subsidiaries and matching firms. This is the first empirical study to examine the effect of foreign tax reform on foreign subsidy in Korea. We believe that our empirical evidence would suggest the tax authorities considering the global change from worldwide tax system to territorial tax system.