「이전가격 세무」 국제조세 관련 대가인 한경배 세무사가 풍부한 경험과 노하우를 담아 집필하였고, 국제조세 관련 이전가격 세무에 대해서 OECD T.P 가이드를 바탕으로관련된 세금 사항을 자세한 설명과 반드시 필요한 신고 서식 등을 적극 활용하여 독자들의 이해를 도왔습니다. 각 부문별로 핵심 체크 포인트를 따로 표기하여, 독자들로 하여금 주의를 환기시키고 반드시 확인해야 할 부분을 명기하여 이해를 도왔으며, 실무에 즉시 활용할 수 있도록 하였습니다.
>>>> 제1장 ∙ 이전가격세제의 개요 ·················································11
제1절 이전가격세제 대상거래 및 제외거래 ······························11
1. 대상거래(사업거래) ·························································11
2. 제외거래(증여거래) ·························································11
제2절 국외특수관계인의 정의 ···················································14
1. 지분소유관계 ··································································15
2. 실질지배관계 ··································································18
3. 제삼자를 통한 실질지배관계 ··········································19
>>>> 제2장 ∙ 정상가격산출방법 ······················································21
제1절 최적방법원칙 ···································································21
1. 최적방법원칙 ··································································21
2. 정상가격산출방법의 적용순서 ········································23
3. 분석대상(Tested party)의 선택 ····································24
4. 쌍방분석과 일방분석 ······················································24
제2절 비교가능제삼자가격법(CUP method) ····························25
1. 적용 요건 ·······································································25
2. 비교가능제삼자가격법의 예시 ········································29
3. 비교가능제삼자가격법의 특징 ········································29
제3절 재판매가격법(resale price method) ····························30
1. 적용요건 ·········································································30
2. 재판매가격법의 예시 ······················································31
3. 재판매가격법의 특징 ······················································31
제4절 원가가산법(Cost plus method) ····································37
1. 적용요건 ·········································································37
2. 원가가산법의 예시 ·························································38
3. 원가가산법의 특징 ·························································38
제5절 거래이익분할법(Profit split method) ···························41
1. 이익분할법의 개요 ·························································41
2. 거래이익분할법의 장점 ···················································41
3. 거래이익분할법의 단점 ···················································42
4. 정확하게 기술된 거래의 성격 ········································43
5. 신뢰할 만한 정보의 확보가능성 ·····································52
6. 결합이익의 결정 ·····························································53
7. 이익분할 ·········································································59
제6절 거래순이익률법(Transactional net margin method) ·· 60
1. 적용요건 ·········································································60
2. 거래순이익률법의 장점 ···················································62
3. 거래순이익률법의 단점 ···················································62
4. 순이익률지표의 선택 ······················································64
>>>> 제3장 ∙ 비교가능성 분석 ························································75
제1절 비교가능성 분석목적과 분석절차 ····································75
1. 비교가능성 분석목적 ······················································75
2. 비교가능성 분석절차 ······················································77
제2절 재화와 용역의 특성 ························································78
제3절 기능(Functions) ·····························································80
제4절 위험(Risk) ·······································································82
1. 위험분석의 의미 ·····························································82
2. 위험관리와 위험부담 ······················································83
3. 위험의 분석절차(국조칙 10조 1항, TPG 1.60) ············86
제5절 거래의 계약조건(Contractual terms) ···························87
제6절 경제적 환경 ····································································87
1. 시장차이 ·········································································87
2. 시장수준차이 ··································································88
제7절 특별한 상황(extraordinary market conditions) ········89
1. 사업전략(business strategy) ·········································89
2. 시장점유정책 ··································································90
>>>> 제4장 ∙ 무형자산 정상가격 결정 ············································93
제1절 무형자산의 개념 ·····························································93
1. 개요 ················································································93
2. 무형자산의 이전가격과 다른 세무문제의 관련성 ···········95
3. 무형자산의 정의 ·····························································96
4. 무형자산의 예시 ·····························································97
제2절 무형자산의 소유와 개발, 향상, 유지, 보호, 사용(DEMPE)···········································103
1. 무형자산의 소유권 및 무형자산 관련 계약조건 ··········105
2. 무형자산과 관련된 기능, 자산 및 위험 ·······················108
3. 거래유형(fact patterns)별 사실관계의 식별 ···············117
제3절 무형자산의 이전 및 사용을 수반하는 거래 ··················120
1. 무형자산 또는 무형자산권리의 이전을 수반하는 거래 ··121
2. 제품판매 또는 용역제공과 관련하여 무형자산의 사용이
이루어지는 거래 ···························································124
제4절 무형자산거래의 정상가격 ··············································126
1. 무형자산거래에 적용되는 일반원칙 ·····························126
2. 무형자산 또는 무형자산권리의 이전 ····························127
3. 거래 당시에 가치평가가 불확실한 무형자산 ···············138
제5절 평가곤란 무형자산(Hard-to-value intangibles) ········140
1. 평가곤란 무형자산의 특징 ···········································141
2. 사후결과를 기준으로 이전가격조정 ·····························142
3. 평가곤란 무형자산에 대한 세무당국을 위한 지침 ·······144
제6절 무형자산의 가치평가기법 ··············································145
1. 가치평가기법의 의미 ····················································145
2. 예상현금흐름 할인가치의 활용 및 그 문제점 ··············146
>>>> 제5장 ∙ 용역거래 정상가격 ··················································151
제1절 용역거래의 식별 ···························································151
1. 가치있는 용역거래 ·······················································151
2. 가치없는 특수관계 용역거래 ········································153
제2절 용역거래의 분석절차 ····················································156
1. 질적 분석 ·····································································156
2. 양적 분석 : 정상대가 산정 ··········································158
3. 총용역원가의 정의 ·······················································161
제3절 용역의 정상가격 산출방법 ············································164
1. 비교가능제삼자용역가격법 ···········································164
2. 용역원가법 ···································································165
3. 용역원가가산법 ·····························································165
4. 거래순이익률법 ·····························································165
제4절 저부가가치용역의 정상가격 ··········································166
1. 저부가가치용역의 범위 ················································166
2. 저부가가치용역의 간주정상가격 ···································167
제5절 금융보증(financial guarantees) ·································168
1. 금융보증의 의미 ···························································168
2. 국내세법의 보증수수료 정상가격 산출방법 ·················169
>>>> 제6장 ∙ 소득조정과 APA ·····················································173
제1절 소득 조정 ······································································173
1. 임시유보 처분 후 처분ㆍ조정 ······································173
2. 임시유보 처분하지 않는 경우 ······································174
3. 반환이자의 계산 ···························································174
4. 반환금액의 순서, 반환받은 것으로 보는 경우 ············176
제2절 정상가격산출방법 사전승인 ··········································176
1. 의의 ··············································································176
2. 절 차 ············································································177
>>>> 제7장 ∙ 정상가격서류의 제출 ···············································181
제1절 국제거래에 대한 자료 제출 의무 ·································181
1. 정상가격산출방법신고서 ···············································181
2. 용역거래에 대한 정상가격산출방법신고서 ···················184
3. 무형자산에 대한 정상가격산출방법신고서 ···················186
4. 국외특수관계인의 요약손익계산서 ·······························188
5. 거래가격 조정 신고서 ··················································190
6. 국제거래명세서 ·····························································190
7. 국제거래에 대한 자료의 제출기한 연장 ······················191
제2절 정상가격산정방법 등의 이전가격서류 제출요구 ···········192
1. 자료제출 요구 ······························································192
2. 자료제출기한 연장신청 및 통지 ··································193
3. 자료제출 불이행 제재 : 증거불채택, 추계과세, 과태료 · 194
제3절 통합기업보고서와 개별기업보고서 ································196
1. 통합기업보고서 작성범위 ·············································196
2. 통합기업보고서 작성의무자 ··········································196
3. 다국적기업그룹에 여러 사업군이 있는 경우 ···············197
4. 자회사별 사업이 다른 경우 : 자회사별 통합기업보고서 ··197
제4절 국가별보고서 ·································································221
1. 국가별보고서 작성범위 ················································221
2. 국가별보고서 제출 면제 ···············································222
3. 국가별보고서 제출의무자 자료 ····································222
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