조세피난처에 대한 국제적 대응과 조세정보교환협정

다국어 초록 (Multilingual Abstract)

This research, centering on the OECD member countries, has taken a look at the international countermeasure against a tax haven which emerged from the latter period of the 1990s. This research began with a restrictive eye on a tax haven and harmful tax competition at first, but there appeared TIEA(Tax Information Exchange Agreement) and information exchange and transparency were emphasized in the developmental process of the research.
With more emphasis on the importance of a tax haven and information exchange after the 2008 financial crisis, OECD Global Forum is leading the stream of international taxes with its initiative in a tax haven. Through such a stream of international taxes, this research is expected to get the implications as follows
First, we cannot be optimistic about the effectiveness of immediately collecting information though we've made an agreement on a tax haven and made TIEA; however, it cannot be denied that such an agreement-making aspect becomes a catalyst to convert from an confrontational approach tax-haven-hosting countries to a conversational approach to them. TIEA-making is the first step toward interaction with a tax haven, and even from now, it is expected that TIEA-making could at least play a role of a restriction line to tax evasion using a tax haven.
Secondly, as the forum for discussing major issues of the world economy moves to G20 from G7, so is the era when OECD takes the unilateral lead in discussions gone. The more the number of the countries participating in OECE Global Forum, the more time and cost it might take for decision-making; nevertheless, OECD Global Forum is proving that such issues as tax evasion and tax avoidance could be resolved effectively only through international countermeasures.
Thirdly, in setting up our direction of tax policy against a tax haven, we shouldn't overlook the importance of TIEA. This research holds that grasping the actual condition on how other countries operate the TIEA made with tax-haven-hosting countries, and going over what role the regulations on information exchange have played in TIEA we have made up until now would be conducive to taking our course of the upcoming agreement policy.

목차 (Table of Contents)

• Ⅰ. 머리말
• Ⅱ. 조세피난처와 有害한 조세경쟁에 대한 OECD의 대항
• Ⅲ. 조세목적의 투명성과 정보교환을 위한 OECD 노력
• Ⅳ. OECD 글로벌 포럼의 영향력 및 TIEA의 확대
• Ⅴ. 조세피난처에 대한 우리나라의 대응 및 방향
• Ⅵ. 맺음말
• 〈참고문헌〉
• 〈Abstract〉

참고문헌 (Reference)

1 백제흠, "피지배외국법인의 유보소득과세제도에 관한 연구" 서울대학교 법과대학원 2005

2 강경숙, "조세피난처 진출법인에 대한 과세정책" 세경사 (2) : 2002

3 안종석, "조세조약 남용에 대한 대응방안 연구" 한국조세연구원 2006

4 홍범교, "역외탈세방지를 위한 제도개선연구" 한국조세연구원 세법연구센터 2009

5 안종석, "국제조세회피의 행태 및 경제적 효과분석" 한국조세연구원 2003

6 윤현석, "국제적 조세회피 방지를 위한 연구 - 조세피난처의 이용과 조세조약 남용방지를 중심으로-" 한국법제연구원 2005

7 鶴田廣巳, "有害な租税競争と国際租税協調" 23 : 2001

8 水野忠恒, "国際課税の理論と課題 (二訂版)" 税務経理協会 2005

9 増井良啓, "タックス・ヘイブンとの租税情報交換条約 (TIEA)" 2009

10 Richard A, Johnson, "Why Harmful Practices Will Continue After Developing Nations Pay: A Critique Of The OECD's Initiatives Against Harmful Tax Competition" 26 : 351-, 2006

11 OECD, "Towards Global Tax Co-operation-Progress in Identifying and Eliminating Harmful Tax Practices"

12 OECD, "The OECD's Project on Harmful Tax Practices: The 2004 Progress Report" 2004

13 OECD, "The OECD's Project on Harmful Practices: The 2001 Progress Report" 2001

14 OECD, "Tax Evasion and Avoidance"

15 OECD, "Tax Co-operation: Towards a level playing field" Assessment by the Global Forum on Taxation 2006

16 OECD, "Tax Co-operation: Towards a level playing field" 2008

17 OECD Forum on Tax Administration, "Study into the Role of Tax Intermediaries" 2008

18 Martin A. Sullivan, "Lessons from the last war on tax havens" 2007

19 J. C. Sharman, "Havens in a storm : the struggle for global tax regulation" Cornell University Press 2006

20 OECD, "Harmful Tax Competition-An Emerging Global Issue"

21 OECD Forum on Tax Administration, "Building Transparent Tax Compliance by Banks" 2009