In this paper, firstly discussions about separate corporate taxation theory and theories of shifting in finance studies in Japan are introduced, and some problems within the theory are pointed out from the standpoint of finance studies. In Japan, corporate taxation has been in essence regarded as a prepayment of personal tax under the Fictional Theory that regards corporations not as taxable objects. In order to explain the nature of corporations, many discussions have used the Entity Theory, arguing that corporations should be treated as entities in their own right. The Entity Theory is an opposite concept to the Fictional Theory. Also, from the standpoint of what the final incidence is, the concepts of shifting and incidence have been explained.
Secondly, pros and cons of the Fictional Theory in Japan are summarized, and the views of Kaizuka(1993), Ishi(1990), and Ushijima(1978 and 1983), which are representative views in Japan about the theory of shifting and incidence, are examined.
Thirdly, the issues of theories of shifting and incidence are examined in this paper. And, an argument of integration is surveyed.
In summary, the most significant problems lie in the great unfairness under the existing imperfect integration.
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