외국계 파트너십의 국내진출에 따른 과세문제
The Issue of Tax by Foreign Partnership's domestic Entry
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In the case of the issue of taxation on foreign partnership, we have to consider the aspect of foreign investment as well as tax yields insurance by deterring tax dodges from the view of source country. There is a tendency that the issue of foreign partnership's taxation system is focused on the case of foreign capital's tax dodges, but we should arrange the taxation system on the foreign partnership by considering followings. First, we should suggest classification basis for the tax status of entities established or organized by foreign law on the base of domestic tax law. Second, we should clarify our standpoint about tax treaty with foreign partnership. Third, we should cope with withholding at source of foreign partnership and the partner with procedure. Fourth, we need a criterion of permanent establishment for foreign partnership.
Abstract
In the case of the issue of taxation on foreign partnership, we have to consider the aspect of foreign investment as well as tax yields insurance by deterring tax dodges from the view of source country. There is a tendency that the issue of foreign partnership's taxation system is focused on the case of foreign capital's tax dodges, but we should arrange the taxation system on the foreign partnership by considering followings. First, we should suggest classification basis for the tax status of entities established or organized by foreign law on the base of domestic tax law. Second, we should clarify our standpoint about tax treaty with foreign partnership. Third, we should cope with withholding at source of foreign partnership and the partner with procedure. Fourth, we need a criterion of permanent establishment for foreign partnership.
참고문헌 (21)
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