Abstract
This is a comparative study of the important problems posed by the imperial finances in Korea and Japan during the late nineteenth and early twentieth centuries, when both states were trying to form a modern financial system, in other words, a 'tax state'. Both had to overcome the 'doctrine of imperial land' (the notion that all lands in the country belong to the sovereign). Korea applied the doctrine of imperial ownership of all land up to the time of the last land survey, never developing doctrines and institutions to justify levying taxes on citizens once their rights to land ownership had been recognised. Japan, however, severed the relation between the king's sovereign power over land and the right to ownership of that land. The doctrine of imperial land' was replaced by the principle that taxes were the expenses paid by the members of the national community for the upkeep of the community. In this regard, it can be said that the concept of taxation in the Japanese Imperial Constitution had advanced one step further than the sovereign's tax of Korea. Even so, the Japanese system failed to establish the reciprocal right of citizens to agree to the levying of taxes.
