국제조세 규제 변화와 국가 간 소득이전 관련 최근 실증연구 동향

In a recent decade, the OECD has released a series of regulations to tackle the intercountry income-shifting of multinational corporations (MNCs). The OECD has taken shape to Pillar 1 and 2 which would bring material changes to the fundamentals of international taxation. The proposal of Pillar 1 and 2 is on the premise that the pervasive income-shifting behavior of MNCs significantly erodes the tax revenue of countries. However, if this premise is untrue or exaggerated, this new international tax reform will cause a wasteful tax compliance burden to MNCs. Therefore, the validity of Pillar 1 and 2 should be reviewed based on empirical evidence from relevant studies. In this light, the present study examines the empirical literature on international tax regulations and yields the following implications. First, the previous literature reports consistent empirical evidence on the effectiveness of information exchange agreements, but conflicting evidence on the role of Country-by-Country Reporting. Second, the transition to the territorial tax system under the TCJA is found to promote income-shifting to lower-tax-rate countries. Meanwhile, the effects of anti-abuse rules of GILTI and BEAT are unclear. Third, recent literature reveals that MNCs determine their level of income-shifting by considering various motivations and non-tax costs. It also reveals that MNCs tend to shift real economic activities, rather than merely shifting book income. Based on this empirical evidence, it is highly uncertain whether Pillar 1 and 2 would achieve its intended policy goals. Therefore, this study recommends taking prudence over the implementation of Pillar 1 and 2.