법인세법상 부당행위계산부인제도와 비정상 특수관계자 거래금액에 관한 연구

초록

The current Corporate Income Tax Law stipulates that the tax authorities can reject related party transactions that unfairly reduce a company’s taxable income. Under this Provision on Rejection of Unfair Transaction, companies are expected to be unable to reduce tax amount through the related party transactions. This study first estimates abnormal related party transaction and then empirically examines whether abnormal related party transactions are associated with corporate tax avoidance. We find an insignificant relation between abnormal related party transactions and tax avoidance. However, we find that abnormal related party transactions are, in part, negatively associated with tax avoidance when the reported earnings are increased by the related party transactions. The results suggest that companies do not use related party transactions as a channel for tax avoidance since they have to pay the inappropreately reduced tax amount once their tax avoidance through related party transactions are uncovered by the tax authorities.

키워드