한국해운선사의 활용경험을 통해 본 주요국의 국제조세리스제도 및 국내 도입에 대한 연구

A tax lease is any lease in which the lessor(the financier) is considered the owner of the leased equipment for income tax purposes. With a non-tax lease, the lessee(the business that received financing and is probably using the equipment)is considered the owner for tax purposes. With a tax lease, the lessor assumes the costs and benefits of ownership, including depreciation and tax credits. Meanwhile, the lessee can claim their monthly lease payments as a business expense for tax purposes. The Cross-border Tax Lease is a kind of tax lease method. A major objective of cross-border tax leases is to reduce the overall cost of financing through utilization by the lessor of tax depreciation allowances to reduce its taxable income. The tax savings are passed through to the lessee as a lower cost of finance. The basic prerequisites are relatively high tax rates in the lessor's jurisdiction, liberal depreciation rules and either very flexible or very formalistic rules governing tax ownership. This study reviews some cases of thr cross-border tax leases have adopted by Korean shipping companies, specially on US and UK cross-border tax leases. US have exclude ships form legislated their tax-lease act considering ship tax-lease is not much profitable, while UK have included ship in their tax-lease act judging from marine transportation is very important to UK. Korean tax authorities need systemic measures to prevent national loss form cross-border tax-lease and restraints of international treaties and methods to maximize their profit with developments of cross-border tax-lease.