인터넷 개인 방송 후원아이템의 과세 체계 및 개선 방안에 대한 검토 ―실질 과세 원칙을 중심으로―

Virtual goods that viewers can use to provide financial support to broadcasters are used on internet streaming platforms. According to prior studies on the legal nature of these virtual goods, unlike other digital items, they possess a high degree of cashability, making them particularly vulnerable to misuse, such as for money laundering. This suggests that they cannot be treated in the same manner as ordinary digital items. Due to these special characteristics, I think that taxation on these virtual items needs to be carried out more precisely in accordance with their substance. However, there are cases where the value-added tax imposed on virtual items is different, and cases where tax invoices are not issued without clear grounds, so there is serious doubt as to whether fair taxation is being carried out in accordance with their substance. An analysis of the tax structure and transaction substance of virtual goods reveals that the existing tax practices have not accurately reflected the actual economic nature of these transactions. Major domestic internet streaming platforms recognize the VAT base as their commission rather than the purchase price. The National Tax Service has confirmed their perception. Although platforms facilitating the use of virtual goods are not subject to the Electronic Financial Transactions Act, hey are, in effect, providing fund transfer services. Users who use donation services perceive the transaction structure as a two-party transfer of funds. This perception suggests that the true nature of virtual goods transactions on internet streaming platforms is a donation. Then, we need to return to the basic principle of the principle of actual taxation and establish a taxation system that is in line with the substance even now. If it is difficult to impose real taxes due to various practical difficulties, then at least there should be no logical contradictions within the taxation system.