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Evaluation points
As new economic transactions are created in a rapidly changing economic environment, corporate accounting procedures are becoming more diverse and are becoming increasingly diversified from traditional ways of calculating taxable income. The book was recognized for its high value in that it systematically and multifacetedly presents the various issues that arise from this situation.
Balancing work and academia
By carefully accumulating and studying specific cases, this book provides highly logical writing that takes into account Professor Kobayashi's practical experience in both the "practical" aspects of accounting and tax assessment and collection, and the "academic" aspects of academic analysis.
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Professor Hiroaki Kobayashi
Graduate School of Professional Accountancy Department of Accounting Profession/Professional Accounting (Concurrent)
Graduated from College of Economics at the University of Tokyo. Joined the National Tax Agency in 1992. Since then, he has served as the Manager of the Iwakuni Tax Office, Deputy Director of the National Tax Agency's Review Office, Professor at Okayama University Graduate School, and Director of the Second Taxation General Manager of the Sendai Regional Taxation Bureau. While employed there, he completed a Master's course at Golden Gate University Graduate School as an overseas researcher at the National Tax Agency, receiving a Master's in Taxation. He has been in his current position since April 2013. His areas of expertise are tax law and tax accounting. He uses his knowledge as a practitioner who has worked at the tax agency for many years to teach students specialized and practical content that is useful in the workplace based on his own experience.
Focusing on the differences in basic thinking between corporate accounting and taxable income calculation
The paradigm shift in accounting and the internationalization of standards are widening the gap with traditional tax thinking
Clarifying the relationship between the two will improve predictability for taxpayers and the government, leading to fair taxation.
In this book, in order to clarify the basic differences in thinking between corporate accounting and taxable income calculations under the Corporation Tax Law, I focus on the gap between the two using taxation cases as material. This book was published in March 2023 with a research grant from the Tax Museum, and at that time I was honored to be selected as a candidate for the Tax Museum Award.
Tax laws and corporate accounting are not valid forever as they were in the past. Every time a new transaction example is devised in economic activity, a new perspective and way of thinking is required. In researching this field, I recognize the need to seek out material in practice and analyze it academically. I believe that my work experience in the government and the questions and knowledge I gained there as the starting point for my research were recognized.
In Japan, taxable income is calculated based on the "final settlement principle." The final settlement principle refers to a system in which taxable income is calculated based on the figures in financial statements approved at the general shareholders' meeting. It is a legal obligation for companies to prepare financial statements and report them at the general shareholders' meeting, so the Corporation Tax Law uses this social infrastructure to calculate income. Financial statements are prepared in accordance with accounting standards, so if the accounting standards change, this has a basic structure that immediately affects tax calculations.
However, corporate accounting, which is the premise of accounting, has undergone a major transformation in the past quarter century. Japan's accounting standards have converged with the International Financial Reporting Standards (IFRS), and in recent years, an increasing number of companies are adopting these as the accounting standards in Japan's financial reporting system. The purpose of financial reports is also to be useful as investment information, and in order to improve this usefulness, accounting procedures that incorporate future forecasts and estimates have been devised, and the content of accounting procedures has changed significantly.
The changes in accounting figures have a significant impact on taxable income calculations, which start from corporate profits under the final settlement principle. Of course, whenever new accounting standards are published, the Corporation Tax Law responds by revising the tax system while determining whether the accounting standards are compatible with taxable income calculations. However, questions must be continually asked, such as whether current corporate profits are capable of bearing tax and whether figures that take into account subjective estimates can be used as the basis for calculating taxable income. I believe that the fundamental issue in research in the field of tax accounting is to what extent taxable income calculations will incorporate the dynamic changes in corporate accounting.
To begin with, accounting and taxes have opposing incentives when it comes to profits. To attract more investment into a company, it is necessary to make profits appear large to investors. On the other hand, when considering tax amounts, the tendency is to want to make profits appear as small as possible. Profits are large as disclosure information, but when filing income tax returns, there is a conflicting desire to make them appear small.
To prevent this, corporate accounting requires the early recording of future expected expenses and losses, and the new accounting standards for revenue recognition prescribe a method of calculating amounts that incorporates the risk of future revenue reductions. On the other hand, taxes place emphasis on legal stability, and require the determination of legal relationships that do not record revenues or expenses based on forecasts or estimates as much as possible. As accounting standards evolve further and attempts are made to take measures that anticipate future risks, it will inevitably conflict with the determinism of taxes.
As the digital economy advances, digital platform operators, such as GAFAM, are able to enter foreign markets without establishing physical bases such as branches or sales offices. As a result, the traditional tax rules that require the existence of such a physical base as a criterion for tax obligations are no longer meaningful. In addition, as the importance of intangible assets, which are a source of revenue in the digital economy, increases, companies are able to reduce their income by transferring important intangible assets to low-tax countries and paying royalties.
In order to respond to these characteristics of the digital economy, the OECD and the G20 have jointly formulated new tax rules, which have been broadly agreed upon. This is a groundbreaking proposal that requires that excess profits made by large digital companies in market countries be distributed among those market countries. Each country is working to institutionalize these new rules, but considerable difficulties are expected in achieving them due to the interests and political conflicts of each country.
Each country has its own taxing power and tax laws are basically domestic; however, just like accounting standards, tax laws are being forced to undergo major changes in order to conform to international trends as a result of globalization.
It is not possible to completely eliminate the difference between the calculation of taxable income based on accounting standards and the Corporation Tax Law, and since accounting and tax have different positions in the first place, I think it is natural that there will be essential differences. However, if the difference between the two becomes larger, practical confusion will arise and it will take a lot of time and money to make adjustments to the calculations to eliminate the difference.
I believe that the current method of calculating taxable income based on corporate accounting, known as the final settlement system, is efficient for Japan's social economy, and that this system should be maintained in principle. I believe that this system can only be operated stably by clarifying the differences and similarities between taxable income calculation and corporate accounting. I believe that this is where the social significance of this research topic lies, and I would like to continue researching this topic.
The material compiled in this book is based on the articles that have been serialized in specialist journals every two months, but as I have been gradually progressing with my research, I have been reminded of many things. There are many things that I have noticed by changing my perspective and looking at things from the outside, which I could not have seen when I was immersed in my work as an official at the National Tax Agency. Also, when you are in Kasumigaseki, you are required to respond quickly and accurately to cases that have a major impact on society. In other words, this is a passive, reflexive response, and unfortunately, the reality is that it is difficult to take the time to think carefully and consider the future.
However, now that I'm at a university, information doesn't flow as quickly as it did in a government office, but I have more time to think than I did back then. When writing a paper, sometimes the logic doesn't become clear unless you take the time to think things through. The work of thinking and coming to a conclusion is the same in my current job compared to my life as a serious minor bureaucrat, but my mindset and pace are completely different.
The research that received this award was done by uncovering and clarifying the differences between taxable income calculation and corporate accounting in light of the famous tax litigation cases that I have experienced, and in terms of its position within my research, it corresponds to a specific theory, so to speak. My future research goal is to summarize the content of this research and theoretically summarize the major framework of the commonalities and differences between the two. If possible, I would like to summarize rules or principles that express the relationship between corporate accounting and taxable income calculation. In some cases, it may be necessary to make proposals with an eye toward legislation.
Ensuring fairness in taxation is the most important theme, and should be called the "lifeline" from the standpoint of enforcement agencies. Currently, aggressive tax planning is seen in companies, particularly foreign-affiliated companies, to skillfully avoid paying taxes, but leaving this unchecked will lead to a decline in awareness of paying taxes. On the other hand, it is also very important that companies that pay taxes properly feel satisfied. I believe that paying correct taxes in a way that companies can be satisfied with will lead to the realization of fair taxation that maintains a sense of fairness for the entire nation, so I would like to further my current research.
For those of you who will be studying accounting and tax in the future, I would like you to have a broad interest in social economics, and if you become interested, you should research it thoroughly and get into the habit of thinking about the significance behind the numbers, the purpose of the system, and how it came about. Repetition of this will surely hone your thinking skills. I believe that Graduate School of Professional Accountancy, where I am a member, can provide a stimulating learning environment that is a well-balanced mix of theory and practice. In order to determine your own career path, I would like you to collect information by looking at literature, attending study groups, and visiting senior students, and use it to help you in the future.
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