지원사업
학술연구/단체지원/교육 등 연구자 활동을 지속하도록 DBpia가 지원하고 있어요.
커뮤니티
연구자들이 자신의 연구와 전문성을 널리 알리고, 새로운 협력의 기회를 만들 수 있는 네트워킹 공간이에요.
초록· 키워드
오류제보하기
The OECD Tax Committee has been adressed its main concern to the international anti-tax avoidance, and has selected the topic of taxation issues relating to international hiring-out of labor as one of the main concerns. It was in a OECD Report which titled in “Taxation issues relating to international hiring-out of labour: in Trends in International Taxation, Paris, 1985,” that the word ‘hiring-out of labor’ was first appeared in the field of international taxation. Reflecting the recommendations contained in the Report, the Commentary para. 8 of Art. 15 of the OECD Model Tax Convention was added for the international hiring-out of labour in 1992.
At first it was intended the judgement criteria as described in the Commentary para. 8 of Art. 15 in the OECD Model Treaty was applied to limit cases of tax abuses, but it was frequently applied to the cases of bona fide companies and employees were being involved. Recognizing these problems, the OECD would launched a task force to review the commentary, and demonstrate a few examples for making the criteria to determine the concept of the true employer in 2004.
And then again in 2007 for the public consultation, revised changes to the Commentary on paragraph 2 of Art. 15 of the OECD Model Tax Convention was introduced. In addition, the results of public consultation since 2007 was reflected in the revised model treaty commentary in 2010.
This article was reviewed that the authorised OECD approach mentioned above would be also applied as a reasonable standard of interpretation by the various Korean authorities.
At first it was intended the judgement criteria as described in the Commentary para. 8 of Art. 15 in the OECD Model Treaty was applied to limit cases of tax abuses, but it was frequently applied to the cases of bona fide companies and employees were being involved. Recognizing these problems, the OECD would launched a task force to review the commentary, and demonstrate a few examples for making the criteria to determine the concept of the true employer in 2004.
And then again in 2007 for the public consultation, revised changes to the Commentary on paragraph 2 of Art. 15 of the OECD Model Tax Convention was introduced. In addition, the results of public consultation since 2007 was reflected in the revised model treaty commentary in 2010.
This article was reviewed that the authorised OECD approach mentioned above would be also applied as a reasonable standard of interpretation by the various Korean authorities.
목차
Ⅰ. 서설
Ⅱ. 국제적 인력송출의 개념과 법률관계
Ⅲ. 조세조약상의 인적 용역소득의 과세관계
Ⅳ. 국제적 인력송출에 대한 과세
Ⅴ. 국제인력송출관련 탈세 기타 남용방지를 위한 최근 논의
Ⅵ. 결론
〈참고문헌〉
〈Abstract〉
참고문헌 (16)
참고문헌 신청
이 논문의 저자 정보
이 논문과 함께 이용한 논문
최근 본 자료
댓글(0)
0
UCI(KEPA) : I410-ECN-0101-2012-329-004217419