대형 베이커리카페와 상속세 회피 가능성에 관한 연구 ：가업승계지원제도의 허점과 개선방안

초록

[Purpose]This study examines whether the Family Business Succession Support System, introduced in 2007 to facilitate intergenerational succession in small and medium－sized enterprises, has been potentially utilized as a vehicle for inheritance tax avoidance through large－scale bakery cafes. [Methodology]Drawing on a mixed－methods approach, this study analyzes large－scale bakery cafes (333㎡ or larger) over the 2014–2023 decade through time－series trend analysis, scenario analysis across asset scales, and typological case analysis of four inspection patterns disclosed by the National Tax Service in January 2026. [Findings]Large－scale bakery cafes grew by 304 percent over the decade, far exceeding the bakery industry (4.2 percent) and coffee shops (8.7 percent), with the surge coinciding with the 2018 expansion of the deduction ceiling. Under the scenario assumptions specified in Tables 3 and 4, tax reduction rates reach 100 percent across asset levels of KRW 5, 10, and 30 billion, as the eligible business assets are fully covered within the family business succession deduction ceiling. 67.9 percent of these cafes are concentrated in the Seoul metropolitan area. Four typologies of potential institutional vulnerability are identified：industry misclassification, real estate commingling, nominal ownership, and sham corporate governance. [Policy Implications]The four typologies of potential institutional vulnerability identified in this study can serve as practical inspection criteria for tax authorities reviewing family business succession deduction applications. Building on these findings, this study proposes four reform directions：realigning eligible industries, reinforcing substantive management requirements, containing real estate investment motives, and recalibrating deduction ceilings and tax rates.

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