ABSTRACT Effective January 1, 1998, Republic of China¡¦s income tax turned from an independent duty to a 2-in-1 system. The move was mainly to eliminate repeated taxation created when it was an independent duty. The move also allowed business tax paid by companies be allocated to shareholders at the same time when distributing bonuses as a deductible item from the combined income tax to be filed by shareholders as individuals, making all business income be levied only once. The new tax system may be good, fair and reasonable, only the poorly prepared maximum deductible amount set by the government to shareholders and the 10% business income tax imposed on pending yield of companies made the new system unreasonable in many ways or kept the system itself from successful implementation. Excessively complicated computing triggered disputes and discontent among taxpayers, making the government taxation even a more difficult task. It is expected that this study, with its discussions and recommendations on the regulations concerning shareholders¡¦ deductible tax rate and 10% business income tax imposed on pending yield of companies in Republic of China¡¦s 2-in-1 tax system, could serve as reference in future amendments waged by the government. As of shareholders¡¦ deductible items, the different times of effectiveness of shareholders¡¦ deductible could create vacuum in leasing plans for businesses, we would like to suggest final accounting estimates of payable or paid income tax into balance of shareholders¡¦ deductible accounts. Owing to the maximum deductible amount set for shareholders, when a company having the income tax paid for the year is different from its financial income or when asked to make up income tax of past years or income tax for pending yield, discrepancy in the definition of income tax given in financial accounting rules and income tax laws would result in deficits in computing shareholders¡¦ deductible rates, making successful allocation less probable. On the contrary, companies eligible for preferential treatments in terms of deductible taxes for investments are exempted from said maximum amount. Further, businesses, either of sole capital or association, having not to establish any shareholders¡¦ deductible account per income tax, are exempted from the maximum amount as well. Besides, it is stipulated in the income tax law that, when a company allocates its yield to directors, controllers as remuneration and bonuses, deductible items must be excluded and totally eliminated. These are all considered to be unreasonable practices as they mean counter -elimination of traditional industry in the Republic of China, making it necessary to review, improve or even revoke the stipulation in the income tax law concerning shareholders¡¦ maximum deductible amount and allocation. In terms of the 10% business income tax imposed on pending yield of companies, the major dispute arisen from the tax reform focuses on the definition of company¡¦s pending yield as specified in the income tax law. Pending yield computed per Art. 66-9 of the income tax law is different from the pending yield given in the financial accounting rules and business accounting law on one hand, on the other, is differs from the text of other provisions of the income tax law. The narrow sense and missing in company¡¦s pending yield defined in the article would allow a company produce pending yield and the 10% business income tax imposed on pending yield could trigger helical effect of additional tax. Further, other issues such as pending yield for stock interests a company is assigned to, the problematic tax deduction for deductible shares of overseas Chinese and foreign shareholders for pending yield, listing of deduction loss reserve for overseas investment when computing pending yield overseas investments conducted by companies as approved by competent authorities, failure to listing pending yield as deduction by a company adjusting or negotiating on adjustment of revenue with tax offices are all unreasonable issues created by the 10% business income tax. Besides, statistics indicate that the 10% business income tax imposed on pending yield of companies does not mean help when it comes to state tax income, it only triggers entangled administrative tasks and disputes. This suggests that the 10% business income tax imposed on pending yield of companies needs discussion or revocation. Finally, we like to discuss the medium and small companies in the Republic of China because of organization scale or cost factor that keep them from establishing sound accounting systems and internal controls that eventually would result in false registered capital, misappropriation of company loans, tax evasion by illegal issuance or access to invoices, the lack of books or even 2 books. The written review system implemented by the government is only created by the lack of manpower and as a way to simplify the procedure. The system allows that businesses having revenues of not exceeding a specific amount and with income subject to allowable adjustments and net yield rates at specific levels be exempted from submitting books, as approval would only be granted on written documents Besides, difference between the revenue subject to allowed adjustment and the revenue registered on books would be listed as deduction as pending yield. Such a system will never invite medium and small businesses establish sound accounting systems and internal controls and become an unfair system to businesses having books and filing their tax and, consequently, needs further discussion and improvements. Key word¡GIntegrated income tax system , Shareholder deductible tax , Undistributed surplus earnings

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本研究將Libby & Luft（1993）所提出之績效模型一般化到現實議題，探討稅務會計人員執行兩稅合一績效之影響因素，將績效分為執行「年度結算申報」、「未分配盈餘加徵10%計算與申報」、「兩稅合一租稅規劃」三工作之績效，知識則依「新」、「舊」分為兩稅合一知識與一般營利事業所得稅知識，並以「教育程度」衡量一般解決問題的能力；以「職業屬性」、「年資」、「在學教育」衡量經驗。研究結果發現： 影響「一般營利事業所得稅知識」高低之因素包含職業屬性、年資，而不受一般解決問題的能力、在學教育(選讀科系)所影響；影響「兩稅合一知識」高低之因素則為職業屬性、一般解決問題的能力及「一般營利事業所得稅知識」，而不受年資及在學教育(選讀科系)所影響。 知識越高者，執行與該知識相關之工作績效越好，故「一般營利事業所得稅知識」高低與執行「期末結算申報」績效呈正相關；「兩稅合一知識」與「未分配盈餘加徵10%的計算與申報」績效呈正相關；「一般營利事業所得稅知識」、「兩稅合一知識」亦與「租稅規劃」相關。 由於績效之衡量是由受試者自行評估，在不認為未分配盈餘加徵10%的相關規定是「新」的知識及受「定錨與調整」經驗法則偏誤影響下，一般解決問題的能力與執行兩稅合一相關工作績效實證結果並無顯著關係。 記帳業者自行評估績效時較會計師樂觀，又受「定錨與調整」經驗法則偏誤所影響。導致記帳業者之知識較會計師業低，但自行評估之績效卻優於會計師業。 受試者皆普遍認為兩稅合一後相關工作較兩稅合一前困難，但除了非上市上櫃公司之稅務會計人員表達不太能勝任外；其他屬性之稅務會計人員則皆「不」認為自己「不能勝任」兩稅合一後相關工作。受試者亦認為外部教育機構所開立之兩稅合一進修班或研討會對其在兩稅合一知識的吸收上，幫助最大。 / This study employees the Libby & Luft's model (1993) to investi-gate the determinants of performance in implementing the new tax system--the integrated income tax system. Three type of tasks performance measured are: filing of tax return, the computation of 10% extra income tax on retained earnings, and tax planning under the integrated income tax system. Knowledge is defined as “specific knowledge in the integrated income tax regulations” and “general income tax knowledge”. General problem-solving ability is measured by education level, and experience is caught by the subject’s career attribute, years of career and school instruction. The conclusion of this study were described briefly as follows: 1. Effects of Experience and Ability on Knowledge acquisition Career attribute and years of career influence “General income tax knowledge”. Specifically, career attribute, general problem-solving ability and “General income tax knowledge” influence “specific knowledge in the integrated income tax regulations”. 2. Relations of Knowledge, Ability and Performance Those who possess more knowledge perform better while they are doing their jobs, which related to what they had learnt before. So, those with sufficient "General income tax knowledge" performs better in “filing of tax return” and those with sufficient "knowledge in the integrated income tax regulations" also performs well in “the computation of 10% extra income tax on retained earnings”. Meanwhile, “General income tax knowledge” and “specific knowledge in the integrated income tax regulations” are related to the “tax planning”. The evaluation of performance is self rated by the subjects. And we find that the agent of bookkeeping and taxation seems to be more optimistic than the CPA does. Since the knowledge score of the agent of bookkeeping and taxation is less than that of CPA, but the self-rating of performance is higher than that of CPA.

本論文探討兩稅合一制所增設的兩個機制，即稅額扣抵比率及加徵保留盈餘稅對上市公司股利發放、資本結構以及公司租稅規劃的影響。首先以數學模式推導出兩稅合一制下這兩個機制與股利發放率及負債權益比率之間的關係，再據以建立研究假說，而後進行兩步驟多變量程序之實證測試。研究所獲致的結果包括： 　　一、兩稅合一制實施後，上市公司稅額扣抵比率與總（盈餘）股利發放率呈正相關，且上市公司稅額扣抵比率愈高者，其總（盈餘）股利發放率、現金股利發放率及盈餘配股發放率皆較兩稅合一制實施前高。由於公積配股並不受兩稅合一制實施的影響，故本文也發現兩稅合一制實施前後公積配股率並無顯著差異。整體而言，兩稅合一制實施後，總（盈餘）股利發放率、盈餘配股發放率及公積配股率較實施前減少，而現金股利發放率較實施前增加。進一步的分析顯示現金股利發放率的增加係受到健全股利政策的推行影響，而盈餘配股發放率的減少可能是受到股票股利緩課取消的影響。 　　二、兩稅合一制實施後，符合促進產業升級條例第八條及第九條規定之投資方案，選擇股東投資抵減之公司並無顯著多於選擇五年免稅之公司，可能原因為選擇五年免稅有利於公司現金流量及每股盈餘的金額。此一結果雖與預期方向相反，但也顯示政府原先擔心公司會選擇股東投資抵減而造成鉅額稅收流失的疑慮並未獲得實證支持。但從兩稅合一實施後公司股權結構的變動分析顯示，公司法人持股比率較實施前增加，而僑外投資持股率較實施前減少，支持公司在不同股東身分稅負差距的考量下，會有股權結構移轉之租稅規劃，以降低股東所負擔的稅負。 　　三、兩稅合一制實施後，上市公司稅額扣抵比率愈高者，股東所享扣抵權愈多，則舉債租稅利益愈少，因而總負債權益比率將降低；而上市公司保留盈餘比率愈高者，所課徵的保留盈餘稅愈高，舉債利息的租稅利益反而增加，會造成總負債權益比率增加。本文的實證結果也顯示，兩稅合一制實施後，上市公司稅額扣抵比率愈高者，其總負債權益比率較實施前低；而上市公司保留盈餘比率愈高者，其總負債權益比率較實施前高。 　　綜合本論文實證結果顯示，兩稅合一制實施後，稅額扣抵比率的機制確實其有消除股利所得重複課稅的效益，進而提高公司股利發放的意願，並且有助於公司資本結構的改善。但是，政府對於未分配盈餘加徵 10％營利事業所得稅的規定卻不利於公司資本的累積，反而提高舉債的租稅誘因，也可能抵銷稅額扣抵比率降低舉債的效果，值得政府深入檢討對公司未分配盈餘課稅的不利影響。 / Enacted in 1998, the Integrated Income Tax System has two important features, i.e., the imputation tax credit to shareholders and the 10% surtax levied on undistributed earnings. Using two-step multivariate regression, this study exmines the impacts of these two features on corporations' dividend payout, tax planning, and capital structure. The findings of this study are as follows : 　　1. After implementation of the Integrated Income Tax System, the imputation tax credit ratio is positively related with total dividends payout ratios. Companies with higher imputation tax credit ratios tend to pay out more cash dividends and earnings stock dividends, ceteris paribus. However, there appears no significant relation between the imputation tax credit ratio and capital stock dividends. On average, after implementation of the Integrated Income Tax System, stock dividend payout ratios, including earning stock dividends and capital stock dividends, are decreased, but cash dividend payout ratios are increased. The increase in cash dividend payout may be affected by the balance dividend policy by the SEC, which require corporations to pay out greater proportions in cash dividends. The decrease in earning stock dividends may be due to the cancellation of the deferral of tax on stock dividends. 　　2. After implementation of the Integrated Income Tax System, inconsistent with the expectation, companies still prefer the five-year tax exemption to the investment tax credits. The results suggest that companies' choices are affected more by such factors as corporate cashflows and earnings per shares. However, after implementation of the Integrated Income Tax System, there is a significant change in stockholder structures, with the ratios of corporation stockholders being increased while the ratios of oversea stockholders being decreased. The opportunity of tax arbitrage will have a significant impact on corporations' stockholder structures. 　　3. After implementation of the Integrated Income Tax System, for companies with higher imputation tax credit ratios, their stockholders will have greater tax benefits, and, hence, the tax benefit for companies to use debt financing is decreased. Conversely, companies with higher ratios of retained earnings will bear more tax burdens on the 10% surtax levied on undistributed earnings; therefore, the tax benefit of debt financing is increased. The empirical results support that, ceteris paribus, companies with higher imputation tax credit ratios tend to have lower debt-to-equity ratios, while companies with higher ratios of retained earnings tend to have greater debt-to-equity ratios. 　　In summary, after implementation of the Integrated Income Tax System, the imputation tax credits reduce the double taxation on stockholders' dividend income and, hence, improve corporations' capital structure. However, the 10% surtax on undistributed earnings may result in opposite effect on corporations' capital structure. The findings of this study have important implications for the government to take into account the potential adverse impacts resulted from taxes levied on corporations' retained earnings.