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Research on the Difference and Implication to the Tax System of Inheritance Tax of Leading Countries - Focussing on the Deduction Tax Rates -
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주요국의 상속세 과세제도 비교 및 시사점 : 인적․물적공제 및 세율제도를 중심으로

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Type
Academic journal
Author
Jung-Woo Suh (창신대학교)
Journal
Korea Tax Reseach Forum Journal of Tax Studies Vol.18 No.3(Wn.41) KCI Accredited Journals
Published
2018.9
Pages
137 - 168 (32page)

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Research on the Difference and Implication to the Tax System of Inheritance Tax of Leading Countries - Focussing on the Deduction Tax Rates -
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Abstract· Keywords

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According to the Statistical Yearbook of National Tax of 2017, the inheritance tax revenue in 2016 was 1.9949 trillion won, marking 0.85% of the national tax which was of an amount of 233.3291 trillion won. However, of the 281,000 deaths, 7,393 are taxed, representing an extremely small percentage of 2.63%. This low level of taxpayers and tax revenues indicates that the inheritance tax does not yet play an active role in achieving the ideal of fair taxation.
In Korea, in the future, the inheritance tax should be seen as attaching more importance to social policy function that suppresses or disperses the concentration of wealth rather than being considered as a tax enhancing the taxation function.
This paper presents comparative analysis of the inheritance tax system of the United States, Japan, Britain, and Germany, focusing on personal allowance, material allowance and tax rate system, and suggests ways to improve Korea"s inheritance tax system from the analysis.
Firstly, with respect to personal allowance such as spousal allowance, child allowance, minors allowance, and allowance for disabled persons, which are allowances in inheritance tax there is a difference in the items and limits between major countries.
Secondly, in relation to the material allowance system, in major countries such as the United States, Japan, the United Kingdom, and Germany, and including Korea, when inheriting (including donation) a family business, there is a sympathy of necessity to reduce the burden of inheritance tax (gift tax) in order to continue the family business. And various types of support system are operating to assure the succession. However, it is necessary to clarify more in detail the boundaries of a family business so that the tax allowance of family inheritance does not help the transfer of personal property wealth but support the continuity of the business managed by professional business person.
Thirdly, in relation to the tax rate system, the minimum and the maximum tax rate of inheritance tax and gift tax differs by country. Also there is a difference in the existence of progressive taxation system. However, when considering the trends in the tax rates of the inheritance tax and gift tax in major countries in the past five years we may be aware that they are moving in the direction of maintaining or increasing the tax burden level.

Contents

요약
Ⅰ. 서론
Ⅱ. 상속세 과세의 일반이론
Ⅲ. 주요국의 상속세 인적·물적공제 및 세율 제도 현황
Ⅳ. 주요국의 인적·물적 공제 및 세율 제도의 비교 및 시사점
Ⅳ. 결론
참고문헌
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UCI(KEPA) : I410-ECN-0101-2018-329-003578960