외국인 투자기업의 조세회피에 관한 연구 : 해외관계사 내부거래를 중심으로

Tax avoidance or tax evasionin international transactions have occupied the attention of the tax authorities for along time. Furthermore, the recent increase in the international transaction volume makes it more important than ever before. However preceding empirical studies on this issue are rare in Korea.This is an empirical study onthe tax avoidance of Foreign-controlled companies (hereafter FCCs). The analysis covers the tax avoidance history of FCCs from 2001 to 2004 when the Enforcement Decree of the Adjustment of International Taxes Act was validated and after the regulation on foreign direct investment was abolished. We analyzed FCCs’ tax avoidance behavior by transfer price. FCCs tend to reduce their taxable income by manipulating the transfer price in internal transactions with overseas affiliates because generally FCCs had heavy internal transactions with overseas affiliates. We analyzed the relationship between the internal transaction weight and the gross margin alienation degree(DIFGR) to observe FCCs’ tax avoidance behavior. The gross margin alienation degree(DIFGR) is a measurement where the gross margin of sample FCC is subtracted by the arm’s length transaction margin. The arm’s length transaction margin is applied by the median gross margin of firms which were in the same industry as the sample FCCs. The result showed that the internal transaction weight negatively relates to gross margin alienation degree.