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
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.
목차
I. 여는 글
II. SC와 국제조세
III. 세법체계상 SC 및 연예인 등에 대한 과세체계 분석
IV. 조세조약상 연예인 등에 대한 과세규정
V. 남아 있는 쟁점 : 세법상 SC법인격 인정 여부
VI. 닫는 글
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