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자산유동화 관련 세무상 몇 가지 문제의 검토 = A Review on Several Tax Issues of Asset Securitization
자산유동화 관련 세무상 몇 가지 문제의 검토  = A Review on Several Tax Issues of Asset Secu...
Contents Info
자산유동화 관련 세무상 몇 가지 문제의 검토 = A Review on Several Tax Issues of Asset Securitization
Material Type  
 기사
ISSN  
12269387
Title/Author  
자산유동화 관련 세무상 몇 가지 문제의 검토 = A Review on Several Tax Issues of Asset Securitization / 양규원
Publish Info  
서울 : 용인송담대학, 1999.
Material Info  
pp. 201-216
Abstracts/Etc  
요약Recently in Sept.,'98, the Law on Asset Securitization was newly legislated. The purpose of the new law is twofold. That is, (ⅰ)to help direct financing of financial institutions and qualified domestic corporations through issuance of securities backed by certain assets such as trade receivables, real estate, etc. (ⅱ) to help improve financial structure of financial institutions and domestic corporations(as measured in terms of debt-to-equity ratio or so-called BIS capital adequacy ratio) by means of off-balance-sheet treatment of the assets to be transferred through asset securitization. In conjunction with the new law now in effective, several tax privileges were also introduced simultaneously in the Tax Exemption and Reduction Control Law. However, several tax issues in the area of value added tax, withholding tax matters, corporate income tax of the Special Purpose Company(SPC), etc. need further clarification or consideration in the future tax legislation process. And some accounting issues are also not dealt in current accounting regulation, the Financial Accounting Standards. In this article, only tax related issues were dealt and reviewed for discussion and suggestion. Such major tax issues are summarized as follows;First, in relation to VAT matters, VAT exemption on all types of revenue of SPC would be in argument in the case that underlying asset of securitization is real estate. That is, under the proposed tax bill in which SPC is characterized as a type of VAT-exempt financial institutions, such revenue of SPC from operation ofreal estate is also to be exempt from VAT whereas VAT exemption on such revenueis not relevant under overall current VAT law structure. Thus, depending on type of the asset securitized, VAT exemption needs to be granted on a selective basis.Second, in computation of corporate income tax of SPC, which is a corporate entity, dividends paid to stakeholders need to be allowed as deduction to avoid double taxation as is the case in taxation of corporate-type mutual fund considering such a fact that SPC is a paper company in economic aspect.Third, in taxation of dividends received by an investor in SPC, such dividends need to be excluded from global income tax return i.e., subjected to withholding tax only in view of other similar cases such as dividends from mutual fund, qualified investment fund for venture companies, etc.
Index Term-Uncontrolled  
자산유동화 관련 세무상 가지 문제의 검토 A Review on Several Tax Issues of Asset Securitization 자산유동화 Asset Securitization 자산유동화증권 Asset-Backed Securities 자산보유자 Originator 특별목적기구 특별목적회사 Special Purpose Vehicle or Special Purpose Company 유동화전문회사 자산관리자 Servicer 원채무자 Obligor 자산보유자의세무 유동화전문회사의 세무 자산유동화증권 투자자의 세무
Added Entry-Personal Name  
양규원
Host Item Entry  
용인송담대학 論文集 : 第2集 1999, 03
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Control Number  
yscl:20506
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