블록체인을 활용한 이전가격세제 개선방안에 대한 연구

Globalisation in the world economy has rapidly increased the cross-border transfer of multinational enterprises(MNEs) goods and services, along with continuous increase of international transactions. As the offshore transaction structure has been complicated, offshore tax avoidance issue such as transfer pricing by taking advantage of different tax regimes in different countries has been growing public concern. Clearly, even though the transfer pricing issue has been discussed over a long period, the ongoing concern might be the information asymmetry, which could lead to trust issue between parties. Due to MNEs' partial disclosure of offshore transaction, taxation issue between MNEs and tax authority could be international tax dispute between the tax authorities of two different countries. To set the efficient and fair taxation on offshore transaction, information asymmetry issue should be resolved first. Blockchain could play a significant role in overcoming the lack of trust between the parties, with the key features of distributed ledger, immutability, transparency, etc. Especially, with the availability of transactional level data through Blockchain Platform, comparable uncontrolled price method is applicable, which could change the traditional transfer pricing method. In the U.S. marijuana research case, where the variances in the state by state legalization and related tax on marijuana, are of trust concern to the federal government, Blockchain, ‘trust machine’, is proposed as a solution. In this case that the federal government was hostile to the variant tax rates on marijuana by states, if we assume the transfer pricing issue due to the different tax rate by countries, as a similar situation, Blockchain is strongly recommended as an idea to solve the inefficient international tax issue, caused by information asymmetry in offshore transaction information.