外國企業 本店經費配賦의 問題點 및 發展方向 : 서비스 기업의 사례를 중심으로
(A) Study on Allocation Methods of Common Expenses Incurred by the Head Office, Etc. of Foreign Corporations in Korea : Focusing on the cases of foreign companies in the field of engineering service)
외국기업 조세 외국법인 공통경비 본점경비 다국적기업 경비;
- 원문 URL
In line with the so-called globalization of the international markets followed by a huge influx of Foreign Multinational Corporations(hereinafter as 'FMC') in Korea, international taxation issues have emerged as important arguments in the logical connection with income-shifting that should contribute to the maximization of those FMCs' global profits. Among other strategies employed by FMCs, the manipulation of transfer pricing has been under tax authorities' keen interest and consistent monitoring but conversely the allocation of common expenses incurred by the Head Office etc. in determining the taxable income of a domestic place of business (permanent establishment) of a foreign corporation, although this is considered to be an easier way for FMCs to shift incomes, doesn't seem to draw much of the authorities' attention resulting in no arrangements on the timely and proper measurements blocking the suspected outflow of economic profits. This study considered that one of the main reasons for the suspected outflow of economic profits is due to the options offered to FMCs by the tax authorities when it comes to application of allocation methods and the authorities' monitoring approaches then tried to survey these points by performing an actual analysis with example FMCs on a small scale. From this analysis we could observe that the blanket allocation method is preferred to the allocation method by each item of accounts, whether intentionally or inadvertently, because of simple calculation system, difficult traceability or tax reasons. Therefore, this study concluded that the tax authorities should change the requirements in NTS Notice No. 2001-10 as stipulating the application of allocation by each item of account for the basic and standard allocation method then allowing partial application of blanket allocation method for limited items only. In light of the fact that we still lack in-depth and actual studies on this subject, I hope more studies would be activated after this.