인문학
사회과학
자연과학
공학
의약학
농수해양학
예술체육학
복합학
DBpia AI
AI 에이전트
AI 아이디어
AI 리더
AI 뷰어
Citeasy
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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.
피인용 0
초록·키워드
A few of celebrities and renowned sportsmen have been known to avoid and/or evade tax by circumventing tax laws. One of the ways to do so is to create a Star Company in a tax heaven region and to compose an employment contract to hire them as an employee of this entity. In that way, they have been able to do their activity in foreign countries by minimizing the tax burden imposed by each country’s legislation and tax treaty.
The Article 17 in the OECD Model Tax Treaty stipulates the possibility of imposing tax to the services by these celebrities to prevent this kind of tax evasions, even though their remunerations were provided by these Star Companies in the form of salary or dividend. However, in the tax treaties South Korea signed with some countries, including the United States, the aforementioned people are not subject to taxation inside the Korean territory, while they offer services and are remunerated as mentioned previously. Reforms in the concerned regulations seem to be needed to level them up to OECD Model Tax Treaty standards.
One of the fundamental problems is whether to accept these star companies as a corporation or not. The form and the content of the piercing the corporate veil differ from one country to another so that a common pattern cannot be discerned. However, better clarification on the piercing the corporate veil seem to be required to prevent the aggressive forms of tax evasions more efficiently.
The Article 17 in the OECD Model Tax Treaty stipulates the possibility of imposing tax to the services by these celebrities to prevent this kind of tax evasions, even though their remunerations were provided by these Star Companies in the form of salary or dividend. However, in the tax treaties South Korea signed with some countries, including the United States, the aforementioned people are not subject to taxation inside the Korean territory, while they offer services and are remunerated as mentioned previously. Reforms in the concerned regulations seem to be needed to level them up to OECD Model Tax Treaty standards.
One of the fundamental problems is whether to accept these star companies as a corporation or not. The form and the content of the piercing the corporate veil differ from one country to another so that a common pattern cannot be discerned. However, better clarification on the piercing the corporate veil seem to be required to prevent the aggressive forms of tax evasions more efficiently.
본문·목차
인공지능 문자 인식 모델을 통해 추출된 텍스트로, 일부 오타나 오류가 포함될 수 있으나 지속적으로 개선 중입니다.
오류를 발견하셨다면 해당 부분을 드래그한 후 ' 를 통해 신고해주세요.
오류를 발견하셨다면 해당 부분을 드래그한 후 ' 를 통해 신고해주세요.
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