부가가치세법상 용역의 공급장소에 관한 비교법적 연구 ― 독일의 부가가치세법을 중심으로 ―

Under the current VAT Act, provisions for the place of supply of services are provided in Article 20, but have not changed since 1977. However, international transactions have increased since the 1990s, and recently, various types of transactions have appeared, such as electronic transactions and consolidated transactions. Therefore, it is difficult to solve the problem of the establishment of international tax jurisdiction in relation to the supply place of the service with the current provision of supply place. In the domain of VAT due to international transactions, double taxation or non-double taxation may occur. To correct this problem, in the case of supply of electronic services through international transactions, Article 53-2 of the VAT Act was newly established and implemented from 2015 in accordance with the view of consumption place as the place of supply. However, it can be seen that intangible services other than electronic services have been solved only through the legal interpretation of the Supreme Court. So it is necessary to consider the place of supply of services under the German VAT Law which has been systematically arranged as a comparative law study for improvement. For this, it is necessary to first solve the problem of classifying goods and services. Regarding the place of supply, Germany's VAT Act provides detailed information by dividing business transactions into B2B and B2C. Therefore, in the VAT Act, it is desirable to regulate the place of supply of services by dividing them into B2C and B2B, as in the case of the EU and Germany, and revising them in the direction of each principle and exception.