국제조세질서와 패권국 -패권국인 미국의 역할과 영향력을 중심으로

International tax law reflects the reality of international politics. This article is written, to an extent, from an international political perspective. For both tax competition and tax information exchange issues, countries tried to solve the problem through multilateral cooperation. An international tax order could not be formed for the area of tax competition because there was no support from the hegemonic United States. However, an international tax order could be formed in the area of tax information exchange thanks to the United States’ strong advocacy for its Foreign Account Tax Compliance Act(FATCA). The United States still maintains its position as a hegemon and has the greatest interest in the issue of multinational corporations’ tax avoidance, so it will exert its influence going forward. Simply refusing to participate will not prevent other countries from taking away U.S. tax sources, which drive the U.S. to actively participate in the discussion. However, unless it prepares a template of model answer, as in the case of tax information exchange, it is highly likely that the U.S. will wait and watch as the international discussion unfolds, and step in to request revisions in favor of its interest when the discussion has progresses to some extent, as in the case of Pillar 1 and Pillar 2. On the other hand, if the public interest in the BEPS issue diminishes over time, the influence of multinational companies on government decision-making will grow again, and the U.S. will induce discussions both within and outside the OECD, if necessary, which could end up aligning with the interests of multinationals. Accordingly, it should be kept in mind that the direction of the solution or the model answer presented by the U.S. may not necessarily be the best answer for all countries.