제1장 국제조세의 기초와 조세조약
1. 국제조세의 개념 ············································································ 3
2. 국제적 이중과세 방지 메카니즘 ················································ 11
3. 국제적 이중비과세의 개념 및 최근의 국제적 대응 동향 ········ 15
4. 국제조세의 효율성을 평가하는 정책 기준 ································ 18
5. 조세조약의 주요 내용 ································································· 22
6. 거주자 개념의 중요성 및 이중거주자 판정 기준 ····················· 28
7. 조세조약과 국내세법과의 관계 ·················································· 37
8. 국제거래에 대한 실질과세원칙의 적용 문제 ····························· 44
9. 국제조세조정에관한 법률상 특수관계 판정 ······························· 49
10. 조세조약과 세법에 반영된 이전가격세제 ·································· 56
제2장 외국기업의 국내원천소득에 대한 과세
1. 외국법인의 판단 기준 및 조세조약의 적용 ······························ 63
2. 우리나라의 외국법인 과세체계 ·················································· 72
3. 외국법인의 국내원천소득 범위 ·················································· 77
4. 노하우와 인적용역에 대한 과세상 구분 기준 ··························· 95
5. 소프트웨어 대가를 사용료(로얄티) 소득으로 취급하는 기준 ··· 99
6. 한⋅미조세조약상 사용료(로얄티) 소득의 원천지국
판단기준 ···················································································· 103
7. 조세조약상 원천징수 관련 혜택을 받기 위한 절차 ··············· 110
8. 외국계 펀드의 실질소유자(수익적 소유자) 판정에 대한
주요 판례 분석 ········································································· 115
9. 고정사업장의 종류 및 판정 기준 ············································ 133
10. 고정사업장 관련 주요 판례 분석 ············································ 169
제3장 BEPS 방지 프로젝트 관련 세제
1. BEPS 방지 프로젝트가 추진된 배경 및 추진 경위 ··············· 183
2. OECD/G20가 추진한 15개 BEPS Action Plan ·················· 193
3. 국제거래관련 이자공제 제한제도의 도입 필요성과 도입
경위 ··························································································· 234
4. 우리나라의 과소자본세제 ························································· 241
5. 소득대비 과다 지급이자 손금불산입 제도 ······························ 251
6. 혼성금융상품거래에 따른 지급이자의 손금불산입 제도 ········ 255
7. OECD/Inclusive Framework의 디지털세 추진경위 ············· 261
8. 디지털세 Pillar 1 과세 방안의 내용 ······································ 270
9. 우리나라 세제에 반영된 Pillar 2 (글로벌최저한세)의
주요 내용 ·················································································· 288
제4장 해외투자시 고려해야 할 세무 이슈
1. 외국납부세액 공제의 종류와 적용방법 ··································· 303
2. 해외자회사 수입 배당에 대한 익금불산입 제도 ····················· 319
3. 조세피난과세(특정외국법인 유보소득 합산과세)제도 ············· 325
4. 거주자의 해외 재산 취득· 보유·처분단계별 세무 이슈 ·········· 359
5. 국외전출세 ················································································· 370
제5장 국제조세 관련 세무행정
1. 상호합의절차의 기능과 주요 내용 ··········································· 383
2. 상호합의절차의 주요 법률적 이슈 ··········································· 401
3. 상호합의절차의 일부로 채택된 중재절차 ································ 408
4. 조세정보교환 제도의 종류 및 운용 메카니즘 ························ 412
5. 조세정보교환 제도의 발전 과정 및 주요 이슈 ······················ 422
6. 해외금융계좌 신고제도 ····························································· 432
