|
|
여러 해외정보들 중에서 일반인과 기업이 필요로 하는 국제법 관련 정보를 신속하게 제공하는 것이 저희의 목적입니다.
본 자료는 국제법률연구원 International Legal Research Institute이 조사하여 제공합니다.
목차
1. Tax haven top 10.초세피난처 규모순 10.
ㅡ Corporate tax haven 4개국
ㅡ General tax haven 3개국
ㅡ Traditional tax haven 3개국
2. Main tax haven 20개국.
3. Unusual cases.
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
1. Tax haven (top 10)
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
In terms of scale, the following ten constantly recur in the top-10 tax haven lists, and in particular all lists ranking by scale (i.e. the quantitive lists):
ㅁ Four modern corporate tax havens (have non-zero "headline" tax rates and require "substance"/employment tax, which leads to very broad tax treaty networks):
ㅡ Ireland
ㅡ Netherlands
ㅡ United Kingdom
ㅡ Singapore
ㅁ Three general tax havens (have non-zero "headline" tax rates but offer some traditional tax haven-type services, which leads to restricted bilateral tax treaties):
ㅡ Switzerland
ㅡ Luxembourg
ㅡ Hong Kong
ㅁ Three very traditional tax havens (open on zero-tax status and no requirement for employment tax/"substance", and thus have limited tax treaties):
ㅡ Bermuda
ㅡ Cayman Islands
ㅡ British Virgin Islands
※ Note the following in regard to this list:
1. Four of the ten have financial centres, namely London, Hong Kong, Singapore, and Zurich, that were in 2017 top 10 Global Financial Centres Index (Luxembourg was 15th).
2. All ten are strongly identified as corporate tax havens, which drives most of the scale in tax avoidance in tax havens.
3. The United Kingdom, having only transformed into becoming a major corporate tax haven in 2009–13 (see U.K. transformation), is sometimes missing from pre-2017 lists.
4. CORPNET's Conduit and Sink OFCs study shows how the bottom 5 in this list (major Sink OFCs), rely on the top 5 (major Conduit OFCs), to "route" flows.
5. Excluding Canada, this list contains the 7 destinations in the world that attracted more than a single U.S. corporate tax inversion since 1983.
6. Six of these are in the top 15 GDP-per-capita (the IMF and World Bank does not include the 3 Caribbean islands, so only the U.K. is missing at #21 rank due to size)
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
2. Tax havens (main 20)
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
ㅁ Sovereign jurisdictions that feature as both major corporate tax havens, and major traditional tax havens, include:
ㅡ Switzerland – both a major traditional tax haven (or sink ofc), and a major corporate tax haven (or conduit ofc), and strongly linked to major sink ofc, Jersey.
ㅡ Luxembourg – one of the largest sink tax havens in the world (i.e. a terminus for many corporate tax havens, especially Ireland and the Netherlands).
ㅡ Hong Kong – the "Luxembourg of Asia", and almost as large a sink ofc as Luxembourg; tied to APAC's largest corporate tax haven, Singapore.
ㅁ Sovereign jurisdictions that feature mainly as major corporate tax havens, are:
ㅡ Ireland – a major corporate tax haven, and ranked by Gabriel Zucman as the EU-28's largest; leader in IP-based BEPS tools (e.g. double Irish), but also Debt-based BEPS tools.
ㅡ Netherlands – a major corporate tax havens, and the largest conduit ofc to tax havens via its IP-based BEPS tools (e.g. the Dutch Sandwich); traditional leader in Debt-based BEPS tools.
ㅡ United Kingdom – After restructuring their tax code in 2009–13 (see U.K. transformation), became a major corporate tax haven; most smaller tax havens are former, or current, U.K. dependancies.
ㅡ Singapore – the major corporate tax haven for Asia (APAC headquarters for most large U.S. technology firms), and key conduit to major Asian sink ofcs, Hong Kong and Taiwan.
ㅁ Sovereign (semi-sovereign) jurisdictions that feature mainly as traditional tax havens (but have non-zero tax rates), include:
ㅡ Malta – an emerging tax haven inside the EU, which has been a source of wider media scrutiny.
ㅡ Cyprus – damaged its reputation during the financial crisis when the Cypriot banking system nearly collapsed, however reappearing in top 10 lists.
ㅡ Taiwan – major traditional tax haven for APAC, and described by the Tax Justice Network as the "Switzerland" of Asia.
ㅁ Sub-national jurisdictions that are very traditional tax havens (i.e. explicit 0% rate of tax), include (fuller list on table opposite):
ㅡ Jersey (United Kingdom), still a major traditional tax haven and strongly connected with conduit ofc Switzerland; issues of financial stability.
ㅡ Isle of Man (United Kingdom), the "failing tax haven"
ㅡ British Overseas Territories, see table opposite, where 18 of the 24 sink ofcs, are current or past, U.K. dependancies:
ㅡㅡ British Virgin Islands, largest sink ofc in the world and regularly appears alongside the Caymans and Bermuda (the Caribbean "triad") as a group.
ㅡㅡ Bermuda, does feature as a U.S. corporate tax haven; only 2nd to Ireland as a destination for U.S. tax inversions.
ㅡㅡ Cayman Islands, also features as a major U.S. corporate tax haven; 6th most popular destination for U.S. corporate tax inversions.
ㅡㅡ Gibraltar – like the Isle of Man, has declined due to concerns, even by the U.K., over its practices.
ㅡㅡ Mauritius – has become a major tax haven for both SE Asia (especially India) and African economies, and now ranking 8th overall.
ㅡㅡ Curacao – the Dutch dependancy ranked 8th on the Oxfam's tax haven list, and the 12th largest sink ofc, but recently made the EU's greylist.
ㅡㅡ Liechtenstein – long established very traditional European tax haven and just outside of the top 10 global sink ofcs.
ㅡㅡ Bahamas – acts as both a traditional tax haven (ranked 12th sink ofc), and ranks 8th on the ITEP profits list (figure 4, page 16) of corporate havens.
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
Unusual cases
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
ㅁ U.S. dedicated entities that do not feature on global tax haven lists:
ㅡ Delaware (United States), a unique "onshore" specialised haven with very strong secrecy laws, but rarely appears on main lists.
ㅡ Puerto Rico (United States), almost a corporate tax haven "concession" by the U.S., but which the Tax Cuts and Jobs Act of 2017 mostly removes.
ㅁ Major sovereign jurisdictions which feature on financial secrecy lists (e.g. the Financial Secrecy Index), but not on corporate tax haven or traditional tax haven lists, are:
ㅡ United States – noted for secrecy, per the Financial Secrecy Index, (see United States as a tax haven); makes a "controversial" appearance on some lists.
ㅡ Germany – similar to the U.S., Germany can be included on lists for its tax secrecy, per the Financial Secrecy Index
The U.S. and Germany would fail the basic "sense-check" of a tax haven, which is whether corporates or individuals re-locate there to avoid taxes.
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
Former tax havens
ㅡㅡㅡㅡㅡㅡㅡㅡㅡㅡ
ㅡ Beirut, Lebanon formerly had a reputation as the only tax haven in the Middle East. However, this changed after the Intra Bank crash of 1966, and the subsequent political and military deterioration of Lebanon dissuaded foreign use of the country as a tax haven.
ㅡ Liberia had a prosperous ship registration industry. The series of violent and bloody civil wars in the 1990s and early 2000s severely damaged confidence in the jurisdiction. The fact that the ship registration business still continues is partly a testament to its early success, and partly a testament to moving the national shipping registry to New York, United States.
ㅡ Tangier had a short existence as a tax haven in the period between the end of effective control by the Spanish in 1945 until it was formally reunited with Morocco in 1956.
ㅡ Some Pacific islands were tax havens but have been curtailed by OECD demands for regulation and transparency in the late 1990s, on the threat of blacklisting. Vanuatu's Financial Services commissioner announced in May 2008 that his country would reform its laws and cease being a tax haven. "We've been associated with this stigma for a long time and we now aim to get away from being a tax haven."
To Find Blueocean, Taste Different Soluton
고도의 국제법 전문가 그룹 ㅡ 국제법률연구원
International Legal Research Institute. 🌐www.ilri.co.kr
Tel. [Korea 82]
Info 24hr. ☏(0)507-1350-0621 / (0)10-5295-0621 / (0)2-557-3476 📧info@ilri.co.kr
Law Dept. ☏(0)507-1351-0621 📧 law@ilri.co.kr
Education Dept. ☏(0)507-1352-0621 📧education@ilri.co.kr
Finance Dept. ☏(0)507-1353-0621 📧finance@ilri.co.kr
Press Dept. ☏(0)507-1354-0621
Administration Dept. 📧administration@ilri.co.kr
Secretary Dept. 📧secretary@ilri.co.kr
Court Auction Dept. ☏(0)507-1420-0621
|
|
|
