부가가치세법상 마일리지(Mileage) 거래에 관한 연구

Mileage program is the most widely and commonly used marketing method among all other customer royalty programs. However, under §61. 4. of Value Added Tax (VAT) regulation simply defines the amount of mileage used as means of payment for any goods received is considered as the base amount of VAT. This one simple clause of VAT regulation is inadequate and too vague to cover current various and complex customer royalty programs, including mileage program, due to issue regarding double taxation, tax neutralization, no regulation for case in which the rewards come in the form of service instead of goods, exempting from VAT when exchanging mileages between two business entities. Consequently, re-establishing solid conceptual framework of VAT regulation toward the mileage program is unavoidable. Throughout this case study, we have focused on the nature of the mileage. There are two primary aims of this study: 1. to investigate if mileage can be considered as a type virtual currencies under VAT regulation since mileage is commonly used as means of payment method from customers stand point of view. 2. to review if mileage can be considered as an exchangeable intangible asset under VAT regulation since mileage is being circulated in the circle of providers, vendors, and customers. We have concluded the nature of closed mileage is the same as sales allowance, so only the closed mileage should be exempt from VAT because the closed mileage is only acceptable between two specific parties, the provider and the customer, and it is meaningless to the third parties. In short, we have analyzed the nature of mileage and provided revising suggestions regarding Value Added Tax regulation according to our research. Our approach of focusing on the nature, we believe, will help us to have clear standard when we decide if a mileage program is applicable to VAT regulation or not even if we have more various and complex customer royalty programs in the future.