관리자
일정기간 동안 제공한 용역이 사업소득인지 기타소득인지 여부




【질의】
수고하십니다.

전 유명 호텔의 조리장으로 지난 이십 여년간 근무해 오다가 새롭게 사업자 등록을 하고 음식점창업자문회사를 개업하였습니다.

인근 음식점에 요리자문을 하면서 소정의 자문료를 받으며 영업을 해오다가 최근 새롭게 시작하는 프렌차이즈 회사와 구두계약을 맺고 일정기간동안 자문을 해주기로 하였으며, 그 과정에서 기존 회사는 폐업신고를 한 상황입니다.

이러한 경우 프렌차이즈 회사에게 제공한 용역은 사업자등록이 말소되었다 하더라도 기타소득이 아닌 사업소득에 해당하는지 알고 싶습니다.

【답변】
거주자가 고용관계 없이 독립된 자격으로 계속적ㆍ반복적으로 용역을 제공하고 지급받는 대가는 사업소득에 해당하는 것이고 일시적으로 용역을 제공하고 지급받는 대가는 기타소득에 해당하는 것으로, 이때 일시적인지 계속적ㆍ반복적인지 여부는 사업자등록의 유무와 관계없이 규모ㆍ횟수 등의 실질내용에 따라 사실판단하는 것입니다(서면1팀-1099, 2006. 8. 8.).

또한, 관련예규에 따르면, 일정기간동안 용역을 계속적ㆍ반복적으로 제공하였다면 일시적인 용역이라고 볼 만한 특단의 사정이 없는 때에는 이를 계속적인 용역제공으로 보아 사업소득으로 구분하도록 하고 있습니다(서면1팀-242, 2006. 2. 23.).

따라서, 귀 질의의 경우에도 일시적인 자문용역의 제공에 해당하는지, 아니면 계속적ㆍ반복적인 자문용역의 제공에 해당하는지에 대한 사실판단에 따라 기타소득 또는 사업소득으로 구분될 수 있는 것으로 사료됩니다. 아래에 관련예규를 첨부하오니 참조하시기 바랍니다.

【문서번호】 서면1팀-242, 2006. 2. 23.

【제목】

용역제공기간(1년) 동안 계속적으로 경영자문용역을 제공하는 경우 일시적인 용역제공이라고 볼 만한 특단의 사정이 없는 한 사업소득으로 구분하는 것임

【질의】

고용관계가 없으며 전문가(변호사, 회계사, 세무사 등)가 아닌자가 특정회사에 비상근으로 지속적인(계약기간 1년) 경영자문을 하면서 매월 정액의 경영자문료를 지급받고 있는 경우 어떤 소득에 해당하는지.

【회신】

거주자가 고용관계 없이 독립된 자격으로 특정회사에 계속적 반복적으로 경영자문용역을 제공하고 그 대가를 지급받는 경우에는 사업소득에 해당하는 것이고 일시적으로 경영자문용역을 제공하고 지급받는 대가는 기타소득에 해당하는 것으로
귀 질의의 경우 용역제공기간(1년)동안 계속적으로 경영자문용역을 제공하는 경우라면 일시적인 용역제공이라고 볼만한 특단의 사정이 없는 한 사업소득으로 구분하는 것이나 이에 해당하는지 여부는 실질내용에 따라 사실판단할 사항임.

DATE : 2011-05-18 11:26
[다음글] 퇴직연금에 가입하면 어떤 좋은 점이 있나요?
[이전글] 사내근로복지기금으로부터 지급받은 학자금 등의 근로소득 및 소득공제 대상 여부
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