• 한국컴퓨터정보학회논문지
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• 제25권10호
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• pp.185-191
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• 2020

본 연구는 디지털 경제하에서 고정사업장 확대로 인한 차입금의 범위가 확대됨으로써 과소자본세제에서 차입금에 대한 지급이자 산정하는 방법을 이전가격과세제도의 정상가격방법으로 일원화하는 방안을 제시하며 정상가격 도출과 관련하여 블록체인 기반 환경 구축에 대한 필요성을 제시하고자 한다. 과소자본세제의 이자공제가 가능한 차입금 금액을 산정 시 이전가격과세제도의 정상가격방법으로 일원화하는 방안은 이전가격세제의 적용범위가 과소자본세제의 적용범위를 포함하기에 조세조약상 및 통상조약상 무차별 원칙이 외국인이 투자한 내국법인과 외국법인의 국내사업장 및 순수내국법인에게도 적용되기에 해결 될 수 있다. 차입금에 관한 '특수관계가 없는 자 간의 통상적인 차입'에 대한 규정 부재에 대한 문제는 블록체인 플랫폼 기반에 공유되는 거래로 인해 차입금에 대한 비교가능한 거래가 투명하게 공유됨으로써 비교가능한 차입규모 및 차입 조건의 범위에 대한 문제점을 해결 할 수 있다. 본 연구는 이자비용을 활용한 소득이전을 방지하고자 하는 과소자본세제제도에 대한 문제점과 개선안을 제시함으로써 정책 입안 및 수행하는 당국에 정책적 방향성을 제공한다는 점에서 본 연구의 공헌점이 있다 하겠다.

• 무역상무연구
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• 제46권
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• pp.351-380
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• 2010

Multinational Enterprises set the prices for transactions between affiliates based principally on their global interest. But the customs authority in Korea wants to set the arm's length price as high as possible to get higher dutiable value for customs purpose, while the internal tax authority in Korea prefers lower arm's length price to get higher value for corporation tax purpose by cutting costs. Problem caused by the inconsistent valuation methods on the same imported goods of the two tax authorities is the single most important tax issue facing multinational enterprises. In the meantime, the customs authority in Korea has thought that it is a universal trend worldwide for the Customs and Internal tax authorities to adopt different methods of valuation on transfer prices between related parties, so KCS couldn't accept APA prices. But the internal tax authority in Korea has taken the initiative in APA program so NTS provided taxpayer with safe-harbor. Recently, KCS created the Advance Customs Valuation Arrangement(ACVA) provisions in the 2008 revision bill of the Customs Act through benchmarking APAs program. Can APAs work for customs? Neither WCO or OECD presents any recommendation on the integration of the valuation methods, but calls for close cooperation between two authorities, which still leaves taxpayers very unstable. We will start to seek ways to integrate the customs valuation and transfer pricing in this study.

• 아태비즈니스연구
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• 제10권4호
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• pp.197-204
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• 2019

The transfer pricing mechanism is a tool commonly used to transfer the tax base from countries with high taxation in countries with low taxation. In many countries, this financial operations generate significant tax revenue losses. In an attempt to limit tax revenue losses, many public authorities have introduced regulations on transfer pricing, but the effectiveness of these rules has proved limited, and they contributed to the increasing complexity of tax laws and to the appearance of additional costs for companies. Historically, transfer pricing (TP) was not a substantial issue in Mongolia. The tax legislation contains basic TP rules, but there is limited guidance and enforcement in practice. At the moment, Mongolian tax authorities are not conducting specific transfer pricing audits. Nevertheless, tax authorities are starting to pay more attention to transactions between related parties and potential transfer pricing adjustments. This study examines a transfer pricing regulations of Mongolia.

• 한국의상디자인학회지
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• 제6권3호
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• pp.31-43
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• 2004

The purpose of this study is to provide basic data on the propriety of the ready-to-made garment sizes of the boys aged between 10 and 11. The data were collected from 315 boys in the capital area. They were surveyed during the period of April, 2004. Data analysis has been performed through descriptive statistics, $x^2$-test, t-test, ANOVA and Duncan test using SPSS ver.10. The results of the analysis are as follows. According to the result of investigating the favorite fashion style of boys, most boys aged between 10 and 11 preferred casual style(jean pants & T-shirts). Boys of age 10 preferred formal style and 11-year-old boys tend to prefer hip-hop style. When boys buy garments, boys aged between 10 and 11 were influenced by their mother or family. The store in which 10-year-old boys purchased their garments was either a children's or a sports wear store, and boys of 11 age prefer young casual wear store. The highest factors of dissatisfaction on buying garments were price and size. According to the result of evaluating fitting problems, the highest degree of dissatisfaction upon proper fitness upper-arm circumference, waist circumference and pants length.

• 산학경영연구
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• 제11권
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• pp.319-341
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• 1998

기업이 해외특수관계자와의 거래시 정상가격보다 높게 또는 낮게 거래하여 과세소득을 해외에 이전시키는 경우 당해 과세당국은 기업의 조세회피를 불문하고 그 조작된 가격을 부인하고 정상가격으로 과세함으로서 자국의 과세권을 보호하고 국제적인 조세회피를 예방하기 위한 이전가격과세제도를 두고 있다. 지금까지의 연구는 주로 유형재화를 중심으로 이루어져 왔으며 무형재화에 대한 연구는 상대적으로 거의 없는 상태이다. 무형재화도 기업이 보유하고 있는 자산중에서 중요한 부분이기 때문에 OECD와 미국에서는 무형재화의 범위에서부터 무형재화의 이전가격결정방법에 이르기까지 수미일관되게 법으로 규정하고 있어나 우리나라는 무형재화의 이전에 따른 규정이 없는 실정이다. 따라서 과세권을 확보하고 국제화에 대비하기 위하여 무형재화의 이전가격세제에 대한 체계적인 규정이 제정되어야 할 것이다.

• 한국의류학회지
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• 제30권2호
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• pp.207-220
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• 2006

The purpose of the study is to develop the basic pattern of casual jacket for men aged between 25 and 34. Compared to the tailored jackets, casual jackets are designed much more diverse form depending on the target customer, price range and moreover fashion trend. Therefore in order to reduce the cost and time of developing new style, pattern draft from the basic pattern is better approach rather than develop each style form the measurements every time. For men's casual jacket pattern draft, the basic pattern of fit and comfort was developed through following research procedures. 173 men were surveyed about their habit of buying and wearing of casual jackets. MDs and pattern designers of 10 casual wear brands for men were interviewed. As a starting point, 3 different basic patterns were selected. 2 patterns were from the 2 interviewed brands and the last one was the pattern of ESMOD. The 3 patterns were studied by means of comparing measurements and general styling. As a results it was found that the pattern of S brand is featuring I silhouette, the pattern of K brand is featuring H silhouette and the pattern of ESMOD is featuring Y silhouette. The results of wearing test showed that the pattern of S brand is the best among the three. They were to add ease around the chest line and waist line, to relocate the waist line and the break point, to increase the jacket length and upper arm width. The improved pattern was made of polyester for the wearing test. The wearing test showed developed pattern was improved significantly. To verify the use of developed basic pattern, two buttoned single jacket was made.

• 한국중재학회지:중재연구
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• 제24권1호
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• pp.45-58
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• 2014

It is a well recognised rule in international law that the property of aliens cannot be taken. The question of whether indirect expropriation and government regulatory measures require compensation is an important issue in international investment law. Bilateral investment treaties and other investment agreements contain brief and general indirect expropriation provisions. These focus on the effect of government action and do not address the distinction between compensable and non-compensable regulatory actions. It is generally accepted that a state is not responsible for loss of property or for other economic disadvantages resulting from bona fide general taxation accepted as within the police power of states, provided it is not discriminatory. Yukos Oil Company is a Russian oil and gas company engaged in exploration, refining, and marketing activities. It is one of the largest oil and gas companies in the world. Yukos Oil Company has its production operations in Russia and markets its products in Europe. An international tribunal ordered the Russian government to compensate a group of Spanish investors for the losses they suffered when Russia seized the Yukos Oil Company on July 26, 2012. This has been the subject of several judicial proceedings and academic publications. This paper explores which circumstances do not lead to taxation amounting to expropriation. The author suggests that under the following circumstances, taxation would not amount to expropriation. First, taxation should be non-discriminatory. Also a lawful exercise of the taxation powers of governments would not amount to expropriation.