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학술연구/단체지원/교육 등 연구자 활동을 지속하도록 DBpia가 지원하고 있어요.
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초록· 키워드
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This paper summarizes the main changes of the 2005 update to the OECD model tax convention, which has been finalized and released for public discussion in the spring of 2005.
The 2005 update includes several main changes to the commentary; Commentary on Article 8 concerning the taxation of profits from shipping, inland waterways transport and air transport, Article 15 concerning the taxation of income from employment, Article 5 concerning the definition of permanent establishment, Article 26 concerning the exchange of information, and Article 18 concerning the taxation of pensions.
The update of the commentary on Article 8 clarifies the definitions of international traffic and ancillary activities to international traffic operation. The profits from international traffic covered in the commentary consist in profits directly obtained from the operation as well as profits from ancillary activities. The ancillary activities are defined as the activities that make a minor contribution and are so closely related to the international traffic operation that they should not be regarded a separate business.
The main update of the commentary on Article 15 is the inclusion of cross-border income tax issues arising from employee stock-option plans. The Article allows the State of source to tax the part of the stock-option benefit that constitutes remuneration derived from employment exercised in that states even if the tax is levied at a later time when the employee is no longer employed in that state.
The main update of the commentary on Article 5 concerns multiple permanent establishments. Permanent establishment issues of a company that is a member of a multinational group as well as a subsidiary company are clarified. It is also added that the mere fact that a person has participated in negotiations will not be sufficient, by itself, to conclude that the person has exercised an authority to conclude contracts in the name of the enterprise.
The commentary on Article is expanded considerably. It reflects current country practices and takes into accounts recent development on the issue of exchange of information. Many of the changes, however, are not intended to alter its substance, but instead are made to remove doubts as to its proper interpretation.
The commentary on Article 18 is also expanded significantly. It includes a number of issues on the taxation of pensions: scope of the Article, cross-border issues related to pensions, allocation of taxing rights, exempt pensions, issues related to statutory social security schemes, issues related to individual retirement schemes, tax treatment of contributions to foreign pension schemes, tax obstacles to the portability of pension rights, and exemption of the income of a pension fund.
The 2005 update includes several main changes to the commentary; Commentary on Article 8 concerning the taxation of profits from shipping, inland waterways transport and air transport, Article 15 concerning the taxation of income from employment, Article 5 concerning the definition of permanent establishment, Article 26 concerning the exchange of information, and Article 18 concerning the taxation of pensions.
The update of the commentary on Article 8 clarifies the definitions of international traffic and ancillary activities to international traffic operation. The profits from international traffic covered in the commentary consist in profits directly obtained from the operation as well as profits from ancillary activities. The ancillary activities are defined as the activities that make a minor contribution and are so closely related to the international traffic operation that they should not be regarded a separate business.
The main update of the commentary on Article 15 is the inclusion of cross-border income tax issues arising from employee stock-option plans. The Article allows the State of source to tax the part of the stock-option benefit that constitutes remuneration derived from employment exercised in that states even if the tax is levied at a later time when the employee is no longer employed in that state.
The main update of the commentary on Article 5 concerns multiple permanent establishments. Permanent establishment issues of a company that is a member of a multinational group as well as a subsidiary company are clarified. It is also added that the mere fact that a person has participated in negotiations will not be sufficient, by itself, to conclude that the person has exercised an authority to conclude contracts in the name of the enterprise.
The commentary on Article is expanded considerably. It reflects current country practices and takes into accounts recent development on the issue of exchange of information. Many of the changes, however, are not intended to alter its substance, but instead are made to remove doubts as to its proper interpretation.
The commentary on Article 18 is also expanded significantly. It includes a number of issues on the taxation of pensions: scope of the Article, cross-border issues related to pensions, allocation of taxing rights, exempt pensions, issues related to statutory social security schemes, issues related to individual retirement schemes, tax treatment of contributions to foreign pension schemes, tax obstacles to the portability of pension rights, and exemption of the income of a pension fund.
목차
Ⅰ. 배경
Ⅱ. 제8조 국제운수소득 주석서 개정 주요내용
Ⅲ. 제15조 종속적 인적용역 주석서 개정 주요내용
Ⅳ. 제5조 고정사업장 주석서 개정 주요내용
Ⅴ. 제26조 정보교환 본문과 주석서 개정 주요내용
Ⅵ. 제18조 연금소득 주석서 개정 주요내용
Ⅶ. 맺는 말
〈참고문헌〉
〈Abstract〉
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