국외여행산업에 대한 영세율 적용에 관한 연구

[Purpose]Since the liberalization of overseas travel in 1989, the travel industry has achieved rapid growth. At the same time, disputes also have arisen between the travel industry and the tax authorities regarding the zero VAT rate to the travel market. Therefore this study finds out the possibility of applying the zero tax rate under the Value Added Tax Act to the overseas travel industry. [Methodology]Firstly, examining each of their assertions of the travel industry and the tax authority on the issue, and referring to the actual regulations on the zero tax rate under the VAT Act and looking for the cases of other countries. Also studying the past authoritative interpretation of the National Tax Service to compare the current VAT taxation status of the travel industry to examine the possibility of application the zero tax rate. [Findings]According to the VAT act, overseas travel is service provision. Overseas is going to be the place where services are provided and facility rights or goods are used in accordance with Article 20 of the VAT Act. By the clauses of the travel contract under the Civil Act, the travel agency must be the travel operator because they bears the responsibility for security of the travel service. Therefore, according to Article 22 of the VAT Act, it is the provision of services occurred in abroad to fall under the zero tax rate. [Implications]Until now, the tax authority has levied value－added tax on overseas travel agencies as they has deemed the travel agencies are making revenue mediating business of overseas travel. However, as shown in the study results, we expect the possibility of reasons for applying a zero tax rate for overseas travel services and institutional improvement.