외국납부세액공제를 통한 국제적 이중과세조정과 문제점에 대한 개선방안

Abstract

Internationalization of economic activities is gaining speed and enlarginging. Therefore, tax problem such as international double taxation has accurred more and more. Reason is simple. There are no borders of economic activities and income. While there are economic activities, accurrence of international double taxation is inevitable. But it is important that such problem of double taxation is hampering positive international investments and economic activities in a globalized world. if problem of double taxation were solved completely by means of current foreign tax credit system, overseas expansion of korean companies will be gaining speed and international competitiveness will also be raised. According to international trends, Japan introduced a new system that dividends from foreign subsidiary are excluded from taxable income and at the same time abolished the system of indirect foreign tax credit. Korea has a strong resemblance to Japan in both tax system and economic environment. So this amendment of tax law in Japan has a huge meaning to system of taxation on foreign income in Korea. In addition, Recently, many countries are changing their systems into an exemption from taxable income(source taxation) on foreign income centered on Europe. Also, U.S.A. is adopting residence tax, but they are considering reduction of corporate tax rates and reform of tax system on foreign income. Like so, international trends of tax system about foreign income are changing. This study reviews why international double taxation come out and its occurrence of type theoretically, and proposes problems and improvement measures on international double taxation adjustment. Also, analyse effect of double taxation adjustment on foreign tax credit through the two cases and comparison of Korean system and Japanese system. Results of this study present the necessity of considering more seriously change to foreign income exemption methods which has already adopted to exclude problem of international double taxation in Europe and Japan.