국제 이동성 인력을 위한 퇴직연금 과세제도 연구

Korea is actively promoting the conclusion of FTAs which remove the international barriers on the service supply. Accordingly it is expected that international labor transfer including intra-company transfer and business investors visits increase gradually in Korea, keeping step with the global trend. International labor transfer is effected by not only the tax system of its resident country but also the source country’s. In both inbound and outbound transfer, it has been recognized that the current tax system in Korea poses the tax issues of international labor transfer with retirement pensions: for taxpayers, tax benefit such as tax deferral for employer contribution is vanished and double taxation is occurred and for tax authority, tax revenue loss befalls. These issues arise from different tax policies on cross-border pension contribution and inappropriate allocation of taxing rights between resident and source countries. Therefore, this research proposes the possible solutions by comparing and analysing the relevant tax rules, in both domestic tax laws and tax treaties, of Canada and the Untied States.