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파생금융상품의 개발을 통한 조세회피와 그 대응방안(Policy response to tax avoidance transactions through DFI in Korea)

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  • 파생금융상품의 개발을 통한 조세회피와 그 대응방안(Policy response to tax avoidance transactions through DFI in Korea)
  • 노영훈
  • 한국조세연구원


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Title 파생금융상품의 개발을 통한 조세회피와 그 대응방안(Policy response to tax avoidance transactions through DFI in Korea)
Similar Titles
Material Type Reports
Author(Korean)

노영훈

Publisher

서울:한국조세연구원

Date 2005-12
Pages 116
Subject Country South Korea(Asia and Pacific)
Language Korean
File Type Link
Subject Economy < Economic Administration
Holding 한국조세연구원

Abstract

In 2005, Korean National Tax Service decided to tax the return on the Japanese currency savings account combined with forward exchange contract. It is the first ruling that the fully hedged foreign currency denominated savings account income as a whole can be treated as interest and subject to withholding tax. The decision was made just one month ago even if the product have been sold by the commercial banks more than 3 years ago with the advertisement that the foreign exchange gain guaranteed by the forward contract are tax-exempt. The purpose of the study is to examine the challenges posed by the Derivative Financial Instrument to individual income tax system in Korean setting. Also, it recommends some interim measures like introduction of transfer tax on regulated financial futures and taxing authorities' publishing tax-avoidance scheme notices to public, before the full-scale tax reform on income tax system incorporating mark-to-market valuation and accrual based tax accounting.