관계기업 간 공동광고선전비의 세법상 분담규정의 문제점과 개선방안

Current corporate tax rule that regulates the allocation criterion for joint advertisement expense can be not adequate to corporation practice.
Results of this study are as follows; First, current corporate tax rule can not reflect the corporate practice of allocating joint advertisement expense into related companies because of advertisement media's diversity and sophistication of costing system. Second, this rule can occur distort of tax equity among consolidated groups, because joint advertisement expenses over some allocation criterion can not be deductible in taxable income. In short, same joint expenses is differentially deductible according to the allocation criterion. Also, this study suggests the following two improvements; First, allocation criterion of each corporations that is reflected their discretion in costing can be accepted. Second, at least groups applying the consolidated tax return system have to be excluded in applying to this corporate tax rule in order to maintain tax equity.