Abstract

Currently, there is taxation in the concrete for operating stage’s income of private schoolpension fund and the taxation for operating stage’s income of public official pension fund wouldbe expected. The corporate tax’s taxation systems are different amoung social security reservepension fund. National pension and military pension fund are classified as non－taxablecorporation, so the operating income of relevant fund do not taxed but public official pension fundand private school pension fund are classified as non－profit corporation, so some operatingincome of these fund are taxed. The purposes of this study are that this study analyzed thetaxation conduit theory application and non－accumulated pension provisions liability regardingsetting of reserve fund for essential business central on operating income of public official pensionfund and private school pension fund based on problem of taxation discord among these funds. This study researched the validity of corporate tax’s taxation for operating income of pension in2 aspects and suggested the logical validity of non－taxation for operating income by setting theoperating income in social security reserve pension fund operating stage as reserve fund foressential business total amount as follows. First, we try to decide the validity of taxation based on character of pension system. Currently,the non－accumulated pension liability’s appropriation on financial statement and appropriation asnational liability incur the social issue. This is considered as income from fund operatingexternally in the essential side of operating income for pension fund but this fund operatingincome has a character as liability which to pay the pension. So, the corporate tax taxation forthis income is not reasonable. Second, we try to decide the validity of taxation based on taxationconduit. The present fund accounting could be considered as conduit of pension accounting. Theoperating income of pension fund is totally paid to pension receiver and the taxation for pension income in pension receipt stage would raise the risk of double taxation, so the corporate taxtaxation for this income is not reasonable on fund operating stage. Afterwards, it is necessary totax on pay stage but taxation for fund operating stage by considering the pension accounting atthe same time and should not tax on pension fund operating income just only by considering thefund accounting as present system. This study could be used as basic data of tax law revision bypointing out these problems and suggesting the improvement plans. The speedy fulfillment of taxlaw revision which was suggested by this study not only keeps the taxation equity among socialsecurity reserve pension fund but also has a significance in that this study suggest the implicationwhich the pension fund has a character as non－accumulated liability and role as taxation conduit,to don not tax on operating stage but to tax on pay stage suggest the non－taxation in the pointof suggesting the validity for income of social security reserve pension fund in operating stage.

Keywords

• public official(private school) pension fund
• non－accumulated pension provisions liability
• reserve fund for essential business
• conduit theory
• accounting standard for pension
• government accounting system
• government debt

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