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The Study On Korean BEPS Action Plan Of Treating Avoidance Of Tax

Posted on:2018-08-04Degree:MasterType:Thesis
Country:ChinaCandidate:X Y WuFull Text:PDF
GTID:2336330512484954Subject:Civil and Commercial Law
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Because of globalization of corporation,development of finance technique and digital economy fields and extra,the international trade volume of multinational enterprises rapidly increased and the multinational enterprises devoted all their energy to the maximum profits in every part of world.The multinational enterprise utilizes unguarded point of each country' s tax treaty and tax law system to conduct avoidance of tax by unduly practice income transfer in the frame of legal activity.However,tax system of every country could not set appropriate measures,so they finally faced the aspect of unable to impose income tax that occurred in one's country.The offensive avoidance of tax from multinational enterprises already became insoluble problem to the individual country.Therefore,in many countries,this kind of deed is considered as political or social problems,so the countries started to aware of the need of whole world' s international tax structure,and OECD made several countries to solve the problem of BEPS(Base Erosion and Profit Shifting)at the same time.OECD and G20 debated several years with member countries,and finally on the final report of BEPS project conveyed 15subject of recommendation at the end of 2015 and forced every member country to follow this rule.China conducted the leading role of mainly leading various conferences about the BEPS project as a member country of G20 and the representative of developing countries.China is a good model of actively confronting BEPS by intangible assets,tax treatment of transfer pricing,preventing abuse of treaty,and specification of transaction of qualified services for deduction,but Korea has not yet proposed any remarkable solution.Fortunately,Korea preannounced active confrontation about BEPS in 2016.For the purpose of arranging effective solution of BEPS,Korea needs to thoroughly examine not only the solution of Europe and America which is advanced countries on the field of international tax,but also the solution of China which actively deals with BEPS and has close relationship with Korea.This among advanced countries' andThis study compares and analyzes the European developed countries and China' s response to the proposal of recommendation about BEPS project.And,suggests the proper solution that fits situation of Korea.In this paper,the structure is divided into four parts:The first part introduces the concept of the BEPS project and the main content.First explain the BEPS project background,meaning,process and characteristics.Then four categories,according to the individual action plan in detail BEPS project results-the main content of the implementation plan and action.The second part introduces the south Korean's response to the BEPS action plan and the overall situation of anti-avoidance system,and evaluate the Korean BEPS action plan anti-avoidance measures.The third part introduces the Chinese and the European and American countries such as the BEPS of dealing with the status quo,reference and BEPS action plan for South Korea's response.First introduced the most positive response to the BEPS BEPS respond to status quo of China,a detailed analysis and evaluation is being put into practice in China's current and future to implement measures.Then introduce and evaluate the European and American countries such as the BEPS project each action plan.The fourth part point South Korea now BEPS the lack of response,and make up for the inadequate response is put forward.In terms of BEPS project related solutions,South Korea legislation deficiency and negative coping.The author analyzes the root causes,and refer to countries such as China and Europe and the United States representative response,suitable for South Korea's economy plan is put forward.
Keywords/Search Tags:BEPS(Base Erosion and Profit Shifting), treatment of transfer pricing, avoidance of tax
PDF Full Text Request
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