Comparative Corporate Tax System of Northeast Asian Countries - Korea, Japan, and China -
Asian Tax Journal Vol. 7 No. 4 (2006), pp. 9-41
Abstract
The Northeast Asian countries such as Korea, Japan, and China all belong to the Continental law system. But the degree of development stages are different. Therefore, the contents of corporate law system are different even though there are some similarity of the legal framework in large. Recently, as the Chinese economy has been developing remarkably, the investment from Korea has been increasing tremendously and the trade volume of two countries is now exceeding that of the United States. Japanese economy also has been recovering from a long-term recession and Korean portfolio investment to Japan has been increasing. Earlier days, Japan invested into China to a great extent. Recently, the tendency has somewhat declined but still the trade volume of two countries also expanding. Historically speaking, Japan introduced an advanced modern corporate tax law as early as in 1884. As Korea was annexed by Japanese Empire in 1910, and in 1916, Korean Peninsula introduced modern corporate tax law. China introduced corporate tax law as late as in 1984 but has rapidly been catching up in order to induce a foreign investment and to accommodate the foreign juridical person and joint venture corporation. The main object of this paper is to introduce somewhat bird-eye view of Japan, Korea, and China corporate tax system and a simple comparison one another, to attain EU-type unified corporate tax system in the long run.
Keywords
- Korea
- Japan
- and China corporate law
- tax rate
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