A tax haven is a legal jurisdiction, which provides a no-tax or low-tax environment. SPC may be a foreign country or principality or dependency or a designated area within a country that has a series of unique characteristics, the primary one being relatively lower tax rates in comparison with other countries or surrounding areas. SPC for leveraged lease is to apply for tax reduction or exemption by establishing SPC at a tax haven. Controlled foreign corporation rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed entities. The rules are needed only with respect to income of an entity that is not currently taxed to the owners of the entity. In other words, FOC registries are criticized, mostly by trade union organizations based in developed countries, especially those of Europe. On the other hand, maritime industry practitioners and seafarers from other countries contest that this is a natural product of globalisation. This paper begins with an analysis of the characteristics of countries that tend to be classified as tax havens. This paper provides an overview of the theoretical insights from a growing scholarly literature that analyzes the implications on the existence of tax haven countries.
Ⅰ. 서론
Ⅱ. 조세피난처 과세제도에 관한 일반적 고찰
Ⅲ. 관련 판례분석
Ⅳ. 조세피난처 세제의 법적 문제점과 대응방안
Ⅴ. 결론
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