지원사업
학술연구/단체지원/교육 등 연구자 활동을 지속하도록 DBpia가 지원하고 있어요.
커뮤니티
연구자들이 자신의 연구와 전문성을 널리 알리고, 새로운 협력의 기회를 만들 수 있는 네트워킹 공간이에요.
초록· 키워드
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Korea is actively promoting the conclusion of FTAs which remove the international barriers on the service supply. Accordingly it is expected that international labor transfer including intra-company transfer and business investors visits increase gradually in Korea, keeping step with the global trend.
International labor transfer is effected by not only the tax system of its resident country but also the source country’s. In both inbound and outbound transfer, it has been recognized that the current tax system in Korea poses the tax issues of international labor transfer with retirement pensions: for taxpayers, tax benefit such as tax deferral for employer contribution is vanished and double taxation is occurred and for tax authority, tax revenue loss befalls. These issues arise from different tax policies on cross-border pension contribution and inappropriate allocation of taxing rights between resident and source countries. Therefore, this research proposes the possible solutions by comparing and analysing the relevant tax rules, in both domestic tax laws and tax treaties, of Canada and the Untied States.
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참고문헌 (18)
참고문헌 신청
Canada Revenue Agency / 2007 / Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention / Income Tax Information Circ
Canada Revenue Agency / 2011 / Guidance for Taxpayers Requesting Tax Treaty Relief for Cross-Border Pension Contribution
De Broe, Luc / 2009 / Tax Treatment of Cross-border pensions under the OECD Model and EU Law / Bulletin for the International Taxation, International Bureau of Fiscal Docume
Fleeman, M Grace / 2008 / Cross-Border Pension Contributions-A US Perspective / The Tax Journal
Freshfields Bruckhaus Deringer / 2012 / Cross-Border pension schemes in the EU, Employment / Pensions and benefits: briefing 233
Canada Revenue Agency / 2011 / Guidance for Taxpayers Requesting Tax Treaty Relief for Cross-Border Pension Contribution
De Broe, Luc / 2009 / Tax Treatment of Cross-border pensions under the OECD Model and EU Law / Bulletin for the International Taxation, International Bureau of Fiscal Docume
Fleeman, M Grace / 2008 / Cross-Border Pension Contributions-A US Perspective / The Tax Journal
Freshfields Bruckhaus Deringer / 2012 / Cross-Border pension schemes in the EU, Employment / Pensions and benefits: briefing 233
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