법인세법상 손익귀속시기 관련 규정 검토 및 개선방안

[Purpose] The purpose of this study is to review the Korean corporate tax law related to recognition of income and to suggest improvement plans. [Methodology] In this study, the relationship between the “doctrine of fixed rights” (the Doctrine) and the accrual basis is reviewed through analysis of laws, Korean case law, conceptual framework, and IFRS, and comparative analyzes were conducted between the all－events test in the US tax law and accrual basis. [Findings] The definition of the Doctrine in Korean case law has substantially the same meaning as the accrual basis (or realization principle). Excluding some provisions that do not meet the all－events test, the cost of sales, service costs, and asset disposal costs, as well as most of the deductibles, are the same as the accrual basis. Therefore it is necessary to delete the laws and regulations that overlap with the accrual basis, and to stipulate that recognition of income is in accordance with the accounting standards, unless otherwise stipulated in the laws and regulations. [Implications] These plans are consistent with the rule that that the timing of recognition comply with accounting standards except for matters otherwise stipulated in the laws. A lots of discussion is needed regarding the establishment of the conceptual framework of the corporate tax law.