- 學位論文
認購權證課稅爭議與股價關聯性之研究
The Relationship between Stock price and Taxation of call warrant
摘要
本文首先簡介認購權證，並且說明我國權證的發行現況及有關的課稅規定。其次，探討特定認購權證租稅爭議事件對於股價的影響。人民與政府的爭議可從行政、司法或立法三個層面尋求解決，由於我國財政部並不同意採行政解釋解決爭端，因此，認購權證課稅爭議僅能透過司法訴訟或立法院修法以茲處理。本文除了對有發行購權證課稅的上市櫃金融證券股執行實證研究外，再將樣本再切割為金控股及證券股二類進行細部研究。對於司法訴訟事件實證結果顯示，在報紙披露八個行政訴訟判決，金融證券股股價對於行政訴訟券商勝訴及敗訴結果均並不顯著，但是剔除金控類股後之證券類股對於敗訴結果有顯著的結論，顯示證券類股對於行政訴訟敗訴結果比金控類股影響更大。對於認購權證課稅修法過程中重要事件進行分析，並列舉6個事件日，其中在首次提案經立法院否決時，與市場預期結果不同，因此，金融證券股股價出現顯著的負的累積異常報酬。認購權證課稅修法案在立法院有6年之久，每個會期都列為重要議案，但都無疾而終，市場似乎未預期修正案能如期通過，於是 96 年6月14日立法院三讀通過增訂所得稅法第二十四條之二時，則其異常報酬及累積異常報酬均屬顯著，以反應投資人對於修正案預期的落差。
並列摘要
First of all, this paper explains call warrants and explains the situation with regards the issuance of warrants and related taxation regulations in the ROC. Then, it studies the influence of specific call warrant taxation disputes on stock value. Civil and governmental disputes can usually be resolved through the three levels of executive, judicial, and legislative branches of government. However because the ROC’s Ministry of Finance does not consent to the use of executive interpretation, call warrant taxation disputes can only be handled through judicial action or by amendments to law by the Legislative Yuan. In addition to the study of actual evidence of taxation of listed financial and securities stocks that issue call warrants, this paper divides the samples into financial stocks and securities stocks for a more detailed study. The results of the study of actual judicial proceedings shows that in the eight judgments disclosed in newspapers, the stock value of the financial and securities stocks were not significantly affected by the results of the administrative proceedings, regardless of whether the securities trader won or lost. However, after omitting financial holdings type stocks, it was concluded that securities type stocks were significantly affected by results that went against the trader. This shows that securities type stocks are more affected by a losing result in administrative proceedings than financial holdings type stocks. Analysis was done on the important events in the process of amending the law on call warrant taxation, and six events are listed. Of these, when the initial bill was rejected by the Legislative Yuan, the market results were different than expected with the stock price of financial securities stocks showing significant negative accumulated abnormal returns. Call warrant taxation law amendments have been before the Legislative Yuan for six years, and each session has listed it as important legislation. However, each bill died before being seriously considered, so the market seemingly did not expect the amendment bills to be passed any time soon. Then, on 14 June 2007, the Legislative Yuan passed an addition to Article 24-2 of the Income Tax Law on the third reading. Abnormal returns and accumulated abnormal returns were both significant features of the amendment, reflecting the different expectations that investors had for the success of the amendment.