간접투자과세제도의 개선방향 = The Study on the improvement of Indirect Investment Taxation

다국어 초록 (Multilingual Abstract)

Fund is an idea correspond to investment trust, investment company and investment management company to execute Indirect Investment under Indirect Investment Asset Management Business Act. The Indirect Investment means collecting funds, etc. from investors to manage the assets falling under investment securities, Exchange trade derivatives, real estate, etc. and to distribute profits accruing from the management of such assets to investors.
The revision of indirect investment taxation is to keep neutrality between direct investment tax and indirect investment tax. To solve the problems must remove double taxation, that is likely to impose tax on the profit accruing from indirect investment and levy tax on investors of indirect investment. The neutrality of tax year and tax arrangement for the investment profits by indirect investment and direct investment has to be carried out as possible. And the Tax Law needs the system to remove discrimination by indirect investment assets.

목차 (Table of Contents)

• I. 문제의 제기
• II. 간접투자의 개념과 유형
• III. 현행 세법상 간접투자과세제도
• IV. 외국계 펀드에 대한 과세 여부
• V. 결론

참고문헌 (Reference)

1 윤현석(Yoon Hyun Seok), "조세조약의 남용 방지" 한국국제조세협회 조세학술논집 22 (1), 2006

2 이태로, "조세법강의" 박영사 박영사, 2013

3 이창희, "세법강의" 박영사 박영사, 2013

4 윤현석, "서울하야식" 2006

5 김미란,안영미, "간접투자에 대한 규제의 통일성 확보방안" 상사법연구 23 (2), 2005