조합 비과세 출자금 과세특례제도 문제점과 개선방안에 관한 연구

Introduced in 1976 to inspire savings of the people and to help build their assets, Non-taxable contribution Special Taxation System that is deposited in credit union is the saving tax subsidies in the Section 9 of “the Special Tax Treatment Control Law” scheduled for abolition in 2018. Therefore, this study suggests the necessity of the system through the comparison of the current situation of the credit unions under the system and the Special Taxation to the employee stock ownership union, and suggests the problems of the current system and suggestions for improvement. The Non-taxable contribution Special Taxation System is considered to have contributed to the increase of the real income of the main member of the credit union and the competitiveness enhancement of the credit union. In view of equality with the corporation, the necessity of this tax preferential treatment is recognized. In particular, when comparing non-taxable contribution introduced to support the formation of union members and the Special Taxation to the employee stock ownership plan, it is considered that the support of the tax system is superior to the special system in terms of the limit of the tax benefit and the diversity of the method. The problem and improvement plan of Non-taxable contribution Special Taxation System are as follows. First, it is the taxation method for the patronage dividends. The surplus of the credit union is distributed to members through the contribution dividend and the patronage dividend, If the contribution dividend is similar to the dividend payout of the corporation, patronage dividend is disposal of surplus, but economic real is similar to mileage system of corporation. Therefore, the patronage dividend is not a preferential tax treatment that should be exempted from dividend income as stipulated in the 「the Special Tax Treatment Control Law」, but it is a property to be prescribed in 「Income Tax Law」 according to the principle of real taxation. Second, There is a possibility that the Non-taxable contribution Special Taxation System may be utilized as a distributed deposit through a financial means wealthy person. Therefore, it is necessary to strengthen the age and income requirements, and to strengthen the membership qualification so that the general people can receive tax benefits in real terms by eliminating the persons subject to comprehensive financial income taxation. Third, in order to reasonably adjust the double taxation on the dividend income of investors who exceed 10 million won, the corporation tax shall be calculated through the credit union tax rate(9%) or actual reduction ratio. Fourth, in order to raise equity with corporations that issue stocks, it is necessary to raise tax exemption of dividend income of current 10 million won or 18 million won and to allow income deduction for investment contribution.