我國政府為了改善所得分配情形、提高高所得者對社會之回饋,財政部在2014年2月提出所得稅法修正草案。草案的重點在於將兩稅合一制,由「完全設算扣抵制」修改為「部分設算扣抵制」(又稱為:兩稅合一新制)。兩稅合一新制的實施,對於企業而言是一種增稅政策,另企業享有的租稅優惠,仍是實質減輕企業租稅負擔,因此租稅成本較沒有無享有租稅優惠之企業低,本研究以Kothari, Leone and Wasley(2005)所建構之裁決性應計項目盈餘管理模型,探討兩稅合一新制實施前後,不同租稅優惠程度之企業,盈餘管理行為是否有不同的差異。 本研究發現,兩稅合一新制實施之時,對享有較多租稅優惠的生技產業之企業所造成的租稅成本較其他無租稅優惠之企業輕,該類企業之管理當局較無將盈餘向下調整之情形 ;對有研發支出之非生技產業之企業所帶來的租稅衝擊較無研發支出之非生技產業之企業輕,該類企業之管理當局亦較無將盈餘向下調整之情形。
In order to improve the situation of income distribution and raise contribution to society from the citizens with high-income, Ministry of Finance proposed an amend draft of tax income system in Feb. 2014. The main point of the draft, as known as Integrated Income Tax System, is changed to Partially Imputation System from Fully Imputation System. For the enterprises, it is a policy of increasing tax, but the tax preferences that the enterprises have can be refleted to reduce the tax burden essentially. Therefore, they have less tax costs than the corporates have less tax preferences. This study was based on Accruals-based Earnings Management model of the Kothari, Leone and Wasley(2005) to investigate the differences of earnings management behavior between enterprises with different tax preference level under the New Integrated Income Tax System. This study found that, after the implementation of New Integrated Income System, the tax costs of the enterprises of biotech industry with more tax preferences are lower then others without tax preferences. There is alos no incentive for them to downside earnings. As well as comparing the enterprises wioutht R&D expenditure of biotech industry, there are less tax impacts on those with R&D expenditure of biotech industry. While the enterprises enjoy more tax preferences and experience less tax impacts, they have less motivation to adjust earnings downwards.