| Summary: | 碩士 === 中原大學 === 會計研究所 === 89 === This study probes on the effects of the integrated income tax over the tax incentives and tax exemption under the integrated income tax system. The corporate income tax has become the tube of collecting individual income tax. Thus, the final tax burden is determined by the stockholder itself. So the tax planning should focus on the individual stockholder, not the corporate. This study concludes that under the integrated income tax system, the effect of the tax exemption in the corporate stage over the tax incentives for the residents is diluted. The tax exemption in the corporate stage includes tax exemption on the income of selling the land、accelerated depreciation、functional investment credit and tax holiday in five year. But for the nonresident, it is still tax-exempted or affected. The investment credit in the individual stockholder stage is still tax-exempted. For the investment in architecture company, traditionally the essential tax planning of architecture companies such as the classification of loans and the allocation of operating expenses is less important on the effect of determining stockholders’ final tax burden then the former taxation system. But the choice of core business and the planning of capital sources are more important then those in the former taxation system. For the tax incentives, the tax exemption in the corporate stage will be traced back in the individual stockholder stage and only has the deferred tax effect under the integrated income tax system. The tax exemption is less important then those in the former taxation system.
On the choice of tax holidays in five years and investment credit, it is beneficial to choose investment credit for the individual stockholder. But in practice, there are still cases of choosing tax holidays in five years instead of investment credit. It shows that the tax burden is not the only determent. And the reason might be as follows：the slow turnover in company’s working capital、the strong demand of fund、the eager to rise the EPS、distributing stock dividends to gain from the market、the pressure of being public listed、compensation plan and the large percentage of foreign investors. And hence there might be an agent problem. On the other hand, the tax auditors should adjust their focus and techniques on corporate income tax under the integrated income tax system. The tax auditors should devoted more efforts auditing on the tax evasion other then the exempted income and investment credit. Finally in a matter of the tax policy, the tax neutrality is not procured in tax incentives under the integrated income tax system and there is a lot more to be reviewed、modified、and improved in the tax incentives.
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