해외투자 세무

제1장 ∙ 총설·············································································7
Ⅰ. 해외투자 관련 국제조세 규정 체계 ······································7
Ⅱ. 해외투자 관련 세법 규정 등 ·················································8
1. 국세 관련 ·········································································8
2. 지방세 관련 ····································································10
3. 조세조약 ·········································································10

제2장 ∙ 해외투자에 대한 관리 ················································13
Ⅰ. 해외투자의 개요 ··································································13
Ⅱ. 해외직접투자 ·······································································14
1. 해외직접투자의 범위 ······················································14
2. 해외직접투자의 신고 ······················································15
3. 해외지사의 설치 ·····························································21
Ⅲ. 외국부동산의 취득 ·······························································24
1. 부동산취득의 신고 및 면제 등 ······································24
2. 신고수리요건의 심사 ······················································26
3. 사후관리 ·········································································27
Ⅳ. 해외현지기업 및 해외부동산의 고유번호 ····························29
1. 해외현지기업에 대한 고유번호 부여 및 관리 ················29
2. 해외부동산에 대한 고유번호 부여 및 관리 ···················32

제3장 ∙ 해외투자에 대한 세무 ················································35
Ⅰ. 해외진출기업에 대한 세무 ··················································35
1. 해외진출형태의 결정 ······················································35
2. 진출형태에 따른 장단점 ·················································37
3. 해외현지법인에 대한 세무 ·············································39
4. 해외지사에 대한 세무 ····················································45
5. 해외주재원에 대한 세무 ·················································50
6. 국외 비거주자 등으로부터 직접 받는 용역대가에 대한 과세
·······················································································55
7. 국외원천소득에 대한 이중과세의 조정 ··························59
Ⅱ. 국외자산에 대한 세무 ·························································71
1. 국외자산 취득 및 보유에 대한 세무 ·····························71
2. 국외자산 양도에 대한 세무 ···········································76
Ⅲ. 국외재산에 대한 증여세 과세특례 ······································86
1. 증여세 납세의무 ·····························································86
2. 국외증여재산의 시가산정 ···············································89
3. 외국납부세액의 공제 ······················································91
4. 국외재산 증여에 대한 증여세 과세 시 준용 규정 등 ··· 93

제4장 ∙ 해외투자에 대한 자료제출 및 해외금융계좌의 신고 ··· 97
Ⅰ. 해외직접투자 등에 대한 자료제출 의무 ······························97
1. 해외현지법인 명세서 등의 제출 ·····································97
2. 해외부동산 취득 등 명세서 제출 ···································98
3. 해외신탁명세 제출 ·························································99
4. 자료제출 의무 불이행에 대한 자료제출 요구 등 ········101
5. 자료제출 의무 불이행에 대한 제재 ·····························102
6. 과태료 부과기준과 불복가능 여부 ·······························105
Ⅱ. 해외금융계좌의 신고 ·························································119
1. 신고의무자 및 신고대상계좌의 범위 등 ······················119
2. 잔액의 환산 및 관련자의 계좌보유 간주 ····················123
3. 신고의무 위반금액의 출처 소명 및 과태료 ·················126
4. 계좌정보에 대한 비밀유지 ···········································129
5. 수정신고 및 기한 후 신고 ···········································130