마일리지 거래의부가가치세법상 취급에 관한 연구 - 주요국의 입법례를 논의 소재로 -

This article reviews the mileage program where points are accumulated by prior transactions and used for purchasing following products. This article reviews two types of mileage program; basic type operated by one entrepreneur and expanded type operated by more than two entrepreneurs. This article reviews provisions related to mileage program from EU VAT directives, UK VAT Act, and Australia's GST Law. In terms of measuring the value of consumption, VAT should be imposed based on the amount consumers had paid. In terms of tax neutrality, the amount of mileage used for purchasing products should not be subject to VAT. In basic type of mileage program, using accumulated mileage is merely using rights for discount, and redeemed products cannot be treated as donation which is subject to VAT. In expanded type of mileage program, payment between entrepreneurs cannot be the 3rd party consideration for the redeemed products. Rather, payment between entrepreneurs should be the independent redemption service and the payment should be deducted for input VAT. For Korean VAT law, the article suggests the amount of mileage used for redemption not be subject to VAT no matter by whom the amount was accumulated. For expanded type of mileage program, if the payment between entrepreneurs takes place when the transaction accumulating mileage occurs, the payment amount should be excluded from taxable amount of that transaction. If the payment between entrepreneurs takes place when the redemption occurs, there should be a procedural process to adjust the amount of VAT paid.