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2017 Fiscal Year Final Research Report

Study on the changing concept of attribution in income taxation

Research Project

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Project/Area Number 16H07037
Research Category

Grant-in-Aid for Research Activity Start-up

Allocation TypeSingle-year Grants
Research Field Public law
Research InstitutionKyushu University

Principal Investigator

TANAKA MASAKUNI  九州大学, 法学研究院, 准教授 (50782950)

Project Period (FY) 2016-08-26 – 2018-03-31
Keywords所得の帰属 / 法律的帰属説 / 経済的帰属説 / 所得課税
Outline of Final Research Achievements

Who should pay the income tax? When the parties related income acquisition have different rights or interests, it is necessary to identify those who collect and converge economic gains on the legal rights or interests. The reason why income is attributed to the person who finally yield economic gains is because in Japan, the country under rule of law, people can control income only based on legal rights or interests. On the other hand, when people deviate from the policy of the law, attribution of income is determined without relying on legal rights or interests. In deciding which of several parties must report a particular receipt, it is important to consider not label of rights, but effect of rights.

Free Research Field

租税法

URL: 

Published: 2019-03-29  

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