의료기관의 법인세 부담 최소화와 관련한 고유목적사업준비금 회계처리의 특성 분석

Based on massive financial statements data gathered from the Korea Health Industry Development Institute, this study investigates comprehensively the tax avoidance and earnings management of medical institutions with accounting of the reserve fund for essential business (“RFEB” hereafter) considering not only the tax decrease effect in RFEB inflow stage but also the tax increase effect in RFEB outflow stage. For that purpose, this study adopts separate variables in analyses reflecting medical institutions’ simple tax avoidance with RFEB, their total tax avoidance with RFEB and related tax reducing factors, and their earnings management with RFEB, respectively. The research sample of this study is provided by, with the help of Korean Accounting Association, medical institutions accounting information disclosure of the Korea Health Industry Development Institute (haspa.khidi.or.kr), which are gathered from the balance sheet and the income distributions of qualified medical institutions and finally consists of 409 firm-years. Specifically, the RFEB can be deductible through general accounting process, while large medical institutions with the obligation of outside auditing are allowed to take separate tax return with deducting the RFEB regardless of accounting process. Out of whole medical institutions, those have taken such separate tax turn are excluded from final research sample of this study. Random-effect panel regression and tobit results show that, first, in case the dependent variable is RFEB net inflow ratio, defined as RFEB net inflow (the minimum of RFEB’s deduction limit and inflow subtracted by outflow) divided by the deduction limit, both default risk and ex-ante tax burden increase the ratio, which can be interpreted that as medical institutions’ financial distress from cash flows become greater, they are more likely to make effort in order to reduce cash expenditures through actively making use of the deduction of RFEB. Second, in case the dependent variable is tax-free RFEB net inflow ratio, defined as RFEB net inflow divided by RFEB’s tax-free deduction limit, default risk reduce the ratio while ex-ante tax burden has insignificant effect on the ratio, which can be interpreted that financially distressed medical institutions are hard to expect additional tax savings effect due to relatively low profitability, and the strength of the tax avoidance, reflecting additional tax savings effect, of such medical institutions is similar to that of others. Third, in case the dependent variable is accounting RFEB net inflow ratio, defined as RFEB accounting net inflow (accounting inflow subtracted by accounting outflow) divided by the sum of pretax net income and RFEB accounting net inflow, default risk reduce the ratio while ex-ante tax burden has insignificant effect on the ratio, which can be interpreted that financially distressed medical institutions are more likely to make effort to report bigger earnings for all greater tax burden, and additional earnings management effort of such medical institutions to make up for lowered profitability, resulting from tax avoidance, is not enough. The results of this study generally implies that medical institutions which have the difficulties in cash supply due to either financial constraint or baseline tax burden are eagerly inclined to use the inflow of RFEB in order to relieve the cash disbursement of corporate income tax. Next, it implies that medical institutions under financial constraint are hard to expect additional tax saving effect with RFEB due to their low profitability, and medical institutions with substantial baseline tax burden are also hard to anticipate it due to the corporate tax law regulations on tax expenses. Finally, it implies that medical institutions which have the difficulties in cash supply due to financial constraint are likely to make efforts to report higher income with RFEB accounting in order to overcome the financial hardship due to their tax avoidance behaviors.