타인을 위한 행위를 할 때 부가가치세의 공급하거나 공급받는 자

By getting other’s help, it is possible to expand the scope of legal or economic activities much more diversely and broadly. Those who engage in legal or economic activities devise and create various types of transactions to achieve their objectives. It is also available to utilize human and material resources in various ways. It is also possible to making use of others. By the way, there are many ways to make use of others. While the legal effects of the others’ actions may be attributed to the others, the economic effects may be attributed to the principal simultaneously. A legal relationship can also be formed in which the legal effect is immediately attributed to the principal when the other person take action. Trust system make it possible to achieve a variety of objectives through consignees. In this way, if the other person intervene in the transaction, there may be more than one party on the side of the supplier or the party on the side of the recipient. If so, there can be a problem of having to choose one from the parties on the supplier side to report and pay the value-added tax. For the side of the recipient, an issue can be formed who is qualified for the input tax credit. At this time, based on the economic effect, it may be considered that the person whom the economic effect is attributed becomes the supplier or the recipient. On the other hand, it shall also be taken into account that value-added tax is imposed on an act of a person participated in a legal or economic activity. If the act meets the requirements of supply, such as supply of goods or services, the supplier bears the tax obligation. The person who performs the act and the person to whom the judicial effect belongs may be different. In this case, one must be selected between the person who performs the act and the person whom the judicial effect is attributed. By the way, the proposition that tax laws should be applied leaving the judicially legal relationship intact is especially emphasized in value-added tax. It should be based on the judicially legal relationships when determining who supplies or is supplied. In this way, the taxpayer can anticipate and act on how taxation would be done according to the judicially legal relationships he or she has intended. In selling or buying through an agent, it is considered that the principal to whom legal effects belong supplies the goods or is supplied with the goods directly in accordance with these standards. In a trust, it is also established by legislation that the trustee, who owns and transacts with the trust property, is obligated to pay value-added tax as a taxpayer. However, the economic profits and losses arising from selling or buying goods on consignment belong to the consignor. The commission agent acts for the consignor. For this reason, when selling or buying goods on consignment it is considered that the consignor directly supplies the goods or is supplied with the goods in value-added tax. But there is no particular reason to be taxed differently in selling or buying goods on consignment. The current legislation, which considers the person to whom the economic effect is attributed supplies or is supplied in only selling or buying goods on consignment, has created a dispute over defining the selling or buying goods on consignment. It is also possible to consider revising the entire regulation on acting on behalf of others. Theoretically, it is sufficient to determine who supplies or is supplied on the same basis as other types of transactions without any separate regulations for acting on behalf of others. Then, so far, there have been separate provisions in relation to selling or buying goods on consignment, selling or buying through an agent, and the cases that supply of goods or services related to trust property. It is obvious that the perception that Value-added Tax Act does separately establish who supplies or is supplied for these transactions has become taken root. Considering these points comprehensively, it can be said that the most realistic way to revise for selling or buying goods on consignment. In other words, it can be revised that it is considered that the commission agent supplies the goods or is supplied the goods in selling or buying goods on consignment by the judicially legal relationships. In addition, there should also be a provisions for when services are supplied, such as quasi-consignment sales. Of course, related provisions such as issuance of tax invoice should also be amended. The continuity of the transaction is cut off between the consignor and the commission agent or between the consignor and the quasi-commission agent with the way above. This problem also occurs when selling or buying through an agent. The same problem arises when the agent supplies the service. It is also necessary to consider how to solve this phenomenon.