조세조약상 고정사업장 과세
Tax problems to permanent establishment on tax treaty
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The domestic tax laws of member countries differ on tax problems of permanent establishment(PE), and the interpretation of OECD Model convention §7 does not harmonize with member countries. This problems bring about double taxation and hamper development of global trading and E-commerce. The CFA of OECD makes progress constantly the study on the Attribution of Profits to PE at 1998 to minimize danger of double taxation on the Attribution of Profits to PE. The OECD Model convention §7 and §7 commentary revision have effect on UN Model convention, tax treaty, domestic tax law. Because tax treaties of all countries have made specially out model of provisions of OECD Model convention and UN Model convention, this revision will have great effect on conclusion and execution of tax treaties. To solve tax problems on PE does establish tax system to coincide with economic substance and has to perform the tax system in practice. Therefore the tax on PE profits in a contrary maintains consistency of tax on another profits. And I think that it is important to make a harmonization the tax system in another contraries concern.
Abstract
The domestic tax laws of member countries differ on tax problems of permanent establishment(PE), and the interpretation of OECD Model convention §7 does not harmonize with member countries. This problems bring about double taxation and hamper development of global trading and E-commerce. The CFA of OECD makes progress constantly the study on the Attribution of Profits to PE at 1998 to minimize danger of double taxation on the Attribution of Profits to PE. The OECD Model convention §7 and §7 commentary revision have effect on UN Model convention, tax treaty, domestic tax law. Because tax treaties of all countries have made specially out model of provisions of OECD Model convention and UN Model convention, this revision will have great effect on conclusion and execution of tax treaties. To solve tax problems on PE does establish tax system to coincide with economic substance and has to perform the tax system in practice. Therefore the tax on PE profits in a contrary maintains consistency of tax on another profits. And I think that it is important to make a harmonization the tax system in another contraries concern.
참고문헌 (9)
- "국세청 국세통계연보"
- "국제조세의 이론과 실무" (2005), 광교 TNS
- "고정사업장 과세방법에 대한 OECD 논의동향", 21(1) (2005), 한국국제조세협회
- "국제금융거래에 따른 소득과세의 정책과제와 제도정비" (2004), 한국조세연구원
- "Report on the Attribution of Profits to Permanent Establishments : Part I General Considerations" (2004)
- "Report on the Attribution of Profits to Permanent Establishments" (2006)
- "General Report The Attribution of Profits to Permanent Establishments" (2006)
- "Report on Attribution of Income to Permanent Establishment" (1994)
- "Transfer Pricing Guidelines for Multinational Enerprises and Tax administrations" (1995)