특수관계자간 이전가격의 관세평가에 관한 사례연구

Abstract

ABSTRACT

The Case Study on The Customs Valuation of Transfer Pricing of Related Parties

Park, Sang-Hoon Advisor : Prof. Lee, Jong-Ha, Ph.D. Department of FTA Business Graduate School of Chosun University

In the past, the price of goods from transaction in trade are usually fixed under perfect competition between the different sides. However, these days the large companies as economy of scale have become the huge multinational corporations due to opening a branches or establishing a foreign branches. When these corporations determine the export price they would be maximizing profit themselves as tax rates structure of the trade partner and interest within the corporations, etc. It is called 'transfer pricing' by tax law. This pricing has difficulty evaluating customs because It can violate equality of tax burden principle compared with parties who are in perfect competition. Though we know that there is problems, it is so difficult to reflect customs law because actually type of international transaction rapidly change, therefore there are problems by failing change. In this study, I want analysis problems of the system of customs evaluation with measures of them according to the disputes between multinational corporations and Korea Customs Service.