ScholarWorks@숙명여자대학교

초록

OECD BEPS Project was initiated by G20 in 2012 and finalized in 2015, which excelled the jurisdiciton to tax on MNE. As a result, local governments in host countries could gain more power to impose tax on source-income of MNEs which have spread GVC widely around the world. This introduction of OECD BEPS Action plan was a dramatic change as well as challenge for MNE to sustain their GVC in local countries. This study was about to analize what OECD BEPS Action Plans have and those implication on the MNEs’ business decision makings. In the paper, 15 BEPS Action plans were summarized in brief, and zeroed in on major issues of action plans which may have relations with MNEs’ business decision in the near future. Then, the researcher found that from the perspective of Korean MNEs, more than any issues drawn from BEPS, Action plans of PE and TP will be bone of business contentions in the future. Nowadays, more than 60 countries are in the process of establishing CbC(Country by Country) implementation plan for imposing source-income tax more than before under the guideline of BEPS Action Plans. As this tendency could not be avoidable for Korean MNEs to sustain global business in host countries, Korean MNEs have to find ways to catch opportunity of re-configurating GVC as a prevention of PE conflicts with host countries, accommodating TP documentation system met for BEPS requirements, and checking existing GVC strategies from the start. In conclusion, Korean MNEs should remember that it is right time to negotiate international taxation uncertainties with host countries when they start to build an entry strategy by way of FDI. Once they miss the chance, it becomes uncertain for Korean MNEs to make a nice exit from host countries without tax conflicts, not to mention of the time when they operate their business in host countries.

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