출국세 과세제도의 도입방안 연구

This is a study on the introduction of measures to the exit tax residents are taxed on unrealized income generated on the resident period. It is already implemented by introducing the exit tax in many OECD countries, and also the exit tax introduced in Japan. Every nonresident individual to whom the exit tax applies. In this study, a review of legislative problems of the introduction of the exit tax. Generally the exit tax is seen as a ‘protective measure’(tax of last chance) but also as a tool to prevent tax-motivated emigration. This article deals with consideration factors to design exit tax. The details are as follows. First, taxpayers of the exit tax should be targeted at non-residents regardless of intention of tax avoidance. The exit tax for tax purposes will be able to find a justification in terms of preserving domestic taxing rights. Second, tax period of the exit tax shall be defined that the taxpayers give up their residence of a country before the date of emigration. Third, in case of switching resident to non-resident, it could be considered(as a verifying method) to confirm the payment of the exit tax by the prohibition of departure in the National Tax Collection Law. Fourth, when introducing the exit tax on securities with limited, allows a deferral(with interest) until the realization of the shares or the death of the shareholder, whichever comes first, provided that proper security is posted. Finally, it is important to overcome tax resistance to establish exit tax, so social consultation to introduce exit tax is essential.