OECD 가상자산 조세정보 보고체계(CARF) 도입과 관련 쟁점에 관한 小考

This paper explores the emerging issues related to the OECD CARF (Crypto-Asset Reporting Framework) and the OECD CARF MCAA (Multilateral Competent Authority Agreement on Automatic Exchange of Information). These frameworks facilitate the exchange of tax-related information on crypto-assets and their transactions among different countries under regulated conditions. Chapter 2 provides an overview of the key components of the OECD Common Reporting Standard for Automatic Exchange of Financial Account Information (OECD CARF) and OECD CARF Multilateral Competent Authority Agreement (MCAA) from a holistic perspective. It also delves into the domestic legal aspects of collecting and exchanging information for crypto-assets and related transaction information, including the Income Tax Act, the Adjustment of International Taxes Act, and the Act on Reporting and Using Specified Financial Transaction Information : Article 164-4 of the Income Tax Act and related enforcement decrees, Article 36 and Article 53 of the Adjustment of International Taxes Act, and relevant articles in the Act on Reporting and Using Specified Financial Transaction Information. This legal analysis of the domestic legal framework and its contents aims to assess the feasibility of implementing the OECD CARF through the current domestic institutions of Korea. Chapter 3 focuses on the OECD CARF commentary suggestions for implementation of the OECD CARF in individual country. It also includes controversial points that provide direct administrative sanctions for non-compliance of Reporting Crypto-Asset Service Providers, as well as measures such as withholding taxes on the reportable users. This chapter discusses critical emerging issues of implementing the OECD CARF.