再建築賃貸住宅의 買入資金 調達을 위한 租稅擔保金融 活用方案 硏究

재건축 임대주택 매입자금 조달에 조세담보금융을 활용하는 방안을 연구했다.

Article 42-1 Item 5 of Urban and Housing Environmental Improvement Act Enforcement Decree allows municipal/provincial governors to acquire reconstructed rental housing before it is sold to public. It states that acquirers must be designated by the Minister of Construction and Transportation when municipal/provincial governors are not allowed to acquire reconstructed rental housing. Designated acquirer may include the Korea Housing Corporation.

The Ministry of Construction and Transportation announced on October 13, 2006 through the "Reconstructed Rental Housing Resources," which was submitted to the National Assembly's National Audit, that rental housing in Seoul area will be acquired by the Mayor of Seoul and rental housing in Incheon/Gyeonggi area by the president of Korea Housing Corporation. However, 76 households in three regions in Seoul that were completed in 2006 will be acquired by the Korea Housing Corporation as Seoul City did not have sufficient budget.

The Korea Housing Corporation has to acquire reconstructed rental housing because local government organizations that have preemptive rights to acquire these rental housing refuse to acquire rental housing due to the lack of budgets. This would cause enormous losses to its business, but the Government has no alternative measures to procure acquisition funds. In this regard, this study examined the use of Tax Increment Financing (TIF) to procure acquisition funds for local governments and analyzed its application to determine its feasibility.

Reconstruction of multi-family housing is generally executed for one complex after another and it is effective to analyze reconstruction complexes with management disposition authorization in order to calculate consumption for acquisition of reconstructed rental housing and tax increment for application of TIF. For this purpose, Samho Garden Apartment Complexes 1 and 2 in Banpo-dong, Seocho-gu were selected. Analysis of subjects followed the following procedures: first, general facts about reconstruction plans were analyzed and the cost of acquisition was estimated.

Second, basic concept of TIF and basic conditions for the estimation of local taxes and tax increments to use in TIF were examined in order to estimate tax increment to use before and after reconstruction based on the reconstruction of apartment complexes. Last, it was analyzed how tax increment can procure cost of acquisition to examine the feasibility of use of TIF. In case of the above subjects, their floor space indexes increased from 189.26% to 242.6% and gross floor area increased by 7,435.88 py from 26,384.47 py to 33,820.47 according to the General Assembly Recordings on Management Disposition (Proposal).

The gross floor area of rental housing to return was 25% of gross floor area to increase (1,858.97 py). Therefore, The Reconstruction Union decided to sell 76 households (24 py models) as rental housing based on the Management Disposition Plans. The cost of acquisition for 76 units of reconstructed rental housing in Samho Garden Apartment Complexes 1 and 2 was KRW 2,810,000 per py of gross floor area according to ‘Reconstructed Rental Housing Pricing Standards (Ministry of Construction and Transportation Notice No. 2005-529)’. For lands, KRW 16,520,000 was multiplied. Therefore, the total cost of acquisition was KRW 17,882,480,000.

Tax Increment Financing is generally based on investing the future tax increment after developing a TIF zone as a separate account during the TIF period. Therefore, TIF begins from examining whether future tax increment could procure the cost of investment for developing a TIF zone. Such tax increment is estimated considering discount rate at the time of TIF execution (reconstruction), increase in equity (land value/building value) after reconstruction, increase in equity with time, and changes in tax rates. The previous equity of Samho Garden Apartment Complexes 1 and 2 was KRW 667,146,050,000 as of March 24, 2006 when the reconstruction project was licensed.

The total equity after development was KRW 896,183,300,000. This total excludes 76 24-py units that are to be sold as rental housing. The annual taxes to consider for TIF (property tax, urban planning tax, and public amenity tax) were KRW 2,601,870,000 before reconstruction, but increased by KRW 893,240,000 to KRW 3,495,110,000 after reconstruction. When tax increment is simply added without considering the value of time and equity value increment, the estimated tax increment to accumulate for the general length of TIF period, which is 23 years, was KRW 20,544,610,000.

The total amount of acquisition for the 76 units of reconstructed rental housing in Samho Garden Apartment Complexes 1 and 2 was KRW 17,882,480,000. As the estimated accumulation of tax during the TIF period was KRW 20,544,610,000, it was found that TIF can be used to procure the total cost of acquisition of reconstructed rental housing. The use of TIF to pay for the acquisition of reconstructed rental housing could apply for all reconstructed complexes in Seoul, Incheon and Gyeonggi-do and could be a feasible solution to solve the problem of procurement of funds for the acquisition of reconstructed rental housing. 도시 및 주거환경정비법 시행령 제41조의2 제5항은 재건축임대주택을 공급하는 경우에는 시‧도지사가 우선 인수할 수 있다.

다만, 시‧도지사가 재건축임대주택을 인수할 수 없는 경우에는 건설교통부장관에게 인수자 지정을 요청하여야 한다고 규정하고 있다. 지정 인수자는 대한주택공사 등이다. 재건축임대주택 인수와 관련 건설교통부는 2006년 10월13일 국회 건설교통위 국정감사에 제출한 ‘재건축임대아파트 관련 자료’에서 서울시 지역은 서울시장이, 인천‧경기지역은 대한주택공사 사장이 인수할 예정이라고 밝혔다. 다만, 서울시의 경우 2006년 인수물량인 3개 지구 76세대는 서울시의 예산이 확보되지 못한 관계로 대한주택공사에서 인수할 예정이라고 보고했다. 재건축임대주택 매입에 우선권을 갖고 있는 지방자치단체는 매입자금 마련이 어렵다는 이유로 인수를 거부하고 있고 이들 지방자치단체를 대신해 재건축임대주택을 인수한 대한주택공사는 막대한 사업 손실이 예상되고 있으나 그 매입자금을 조달하기 위한 정부의 대책은 전무한 실정이다. 따라서 본 연구는 재건축임대주택에 대한 지방자치단체의 매입자금 조달방안으로 ‘조세담보금융(Tax Increment Financing ; TIF)’ 활용을 검토, 이에 대한 적용사례를 분석하여 그 적용 타당성을 판단했다.

공동주택 재건축사업은 단지별로 진행되는 것이 일반적이며 재건축임대주택 인수를 위한 소요비용, 조세담보금융 적용을 위한 세액의 증가분 등을 산출하기 위해서는 관리처분인가를 받은 재건축단지를 대상으로 분석을 진행하는 것이 효과적인바 이러한