지방세법상의 건설자금이자에 대한 연구

Abstract

Acquisition tax is a local tax imposed on asset acquisition and its tax base is determined by acquisition price when the price is provable by objective documents. Although acquisition price is required to include direct and indirect costs necessary to acquire the assets, local tax law does not include detailed guidelines of how to include such costs in the tax base. This study focuses on one of the indirect cost of asset acquisition, interest on self-constructed assets and discusses capitalization of such interest when production activities cease.
 In financial accounting, some claim that interest on self-constructed assets should be capitalized because the interest is an acquisition cost, but others insist that interest is an expense incurred in financial activity, not in pro- duction activity, so it should be expensed. Current local tax law requires firms to capitalize interest for self-constructed asset regardless of how it is reported for the purpose of financial accounting. In addition, interest is capitalized even when construction ceases. Some practitioner and scholars are against such approach of tax law because it differentiates tax bases of the same asset acquisitions based on financial resources and construction periods.
 This study proposes that the local tax law allows taxpayers to cease interest capitalization for self-constructed asset unless they cease due to circumstances inherent in the production process. It is against the tax equity that the difference in acquisition periods results in the difference in acquisition tax amount for the same assets. New regulation may include when capitali- zation of interest can cease. In addition, it may also include that the suspen- sion of interest is an election made by a taxpayer and taxpayers are responsible for demonstrating that a cessation is not inherent in the production process. This study is expected to contribute to practitioners and policy makers by proposing new regulations in determining tax base of acquisition tax.