관리자
직원에 판매인센티브 지급시 원천징수의무 여부 및 원천징수 시기




【질의】
당사는 현재 건설 중에 있는 리조트를 외부업체를 통하여 분양하고 있는데, 분양활성화를 위하여 내부 직원이 분양하는 경우 외부업체에 지급하는 대행수수료의 50%에 상당하는 금액을 분양인센티브로 지급하고 있습니다.

분양인센티브(대행수수료의 50% 상당액)는 분양계약시와 중도급 납입시에 각각 대행수수료의 10% 상당액을 지급하며, 대행수수료의 30% 상당액은 적립하였다가 차후 당해 직원이 리조트를 구입하는 경우 해당 금액만큼 할인해주는 형태입니다.

당초에는 위에 따라 적립된 금액을 당해 연도말까지 사용하지 않으면 소멸하는 것으로 정하였다가 현재는 내년 말까지로 연장한 상태입니다.

이 경우 분양인센티브의 현금 지급분과 적립금 부분에 대한 각각의 원천징수의무 여부와 그 시기에 대해 질문드립니다.

【답변】
과세관청의 관련예규에 따르면, 근로자가 기본급여 이외에 판매실적에 따라 사용자로부터 추가로 지급받는 판매장려금과 수당 등은 근로소득에 해당하는 것으로 보고 있는 바(소득 1264-4444, 1982. 12. 28. ; 조심 2008중 3481, 2008. 12. 23.), 귀사가 직원에게 지급하는 분양인센티브의 경우에도 당해 직원의 근로소득에 해당할 것으로 보입니다. 다만, 현금으로 지급하는 분양인센티브는 지급시에 동 직원의 근로소득이 되는 것이나, 적립금으로 적립하는 경우에는 적립시가 아닌 동 적립금의 사용시에 직원의 근로소득으로 인식하는 것이 타당할 것으로 판단됩니다(서면1팀-1042, 2006. 7. 25.).

한편, 소득세법 제134조에서는 원천징수의무자가 갑종에 속하는 매월분의 근로소득을 지급하는 때 근로소득간이세액표에 의하여 소득세를 원천징수하도록 규정하고 있는 바, 귀사의 경우에도 동 규정에 따라 직원에 지급하는 인센티브에 대해 원천징수의무가 있을 것으로 판단됩니다.

여기서 매월분의 근로소득이란 당월에 귀속될 급여 및 수당과 상여금을 합산한 금액에서 비과세 근로소득을 제외한 금액을 의미합니다. 또한, 매월 원천징수대상이 되는 근로소득에는 분기별로 지급되는 상여금이나 기타 부정기적으로 지급되는 수당 등을 귀속기간 월수에 따라 당해 월에 배분한 금액을 포함합니다.

따라서, 귀사가 직원에게 현금으로 지급한 금액과 적립금 중 직원의 사용액은 매월분의 근로소득에 포함하여 소득세법 제136조 제1항의 규정에 따라 계산한 금액을 동법 제134조 제1항의 규정에 따라 원천징수하여야 할 것으로 판단됩니다.

DATE : 2010-05-18 21:15
[다음글] 비사업자인 개인에게 차량사용료 등을 지급하는 경우 원천징수 여부
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