[의견서] OECD 디지털세 “통합접근법(Pillar One)” 항의서 제출
OECD 디지털세 “통합접근법(Pillar One)” 에 대한 항의서 제출
한국시민사회는, 디지털세의 과세대상을 소비자대면사업을 대상으로 하는 다국적 IT기업들과 동일한 범주에서 글로벌 공급망을 기반으로 하는 소비재 제조업에 확대 적용하려는 이 통합접근법(안)에 대해, “제조기업들이 갖는 유형자산과 달리 IT기업들의 무형자산이 갖는 비물리적 현존성에 기인한 소득이전 및 세원잠식 능력과는 상당이 다르다”는 취지에서 OECD에 강력한 항의 의사를 표명하는 바, 이에 따라 우리는 <제1핵심의제에 따라 제안됐던 OECD 사무국의 “통합접근법(안)”>에 대한 항의 의견서를 전달한다.
다운로드: [CCEJ] Comments by Korean Civil society (En) Rev.2
【영문요약】
COMMENTS BY KOREAN CIVIL SOCIETY
before
OECD / G20
Review of the OECD’s proposed “Unified Approach” under Pillar One
Citizens’ Coalition for Economic Justice [1]
Republic of Korea
November 12, 2019
1. Of particular interest to a new digital tax, actual and fair taxation to be required for multinational IT companies (“IT-MNEs”) in a concentration of digital-economic powers with their non-physical presence to fall under the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), is the international society so having reached a meeting of our minds on the basic purpose of setting the OECD/G20 BEPS Actions. And we were going to do so. We already knew the global market was more and more integrating between digital economy and international trade, the fact that the early report by OECD (2015) estimated indicating about 4–5% losses of the global corporate income tax revenue, (i.e.), annually 100–240 billion dollar, due to these IT companies, (e.g.), Google, Apple, Facebook, Amazon, et al. They did. Those lions’ share hadn’t got to be above our suspicion at their tax evasion through transfer pricing. We were supposed to do our fair share, would be fixed to take their unfair share into our taxable income, and now we’re opening the door of possibility to set the new nexus and profit allocation rules into the OECD’s proposed “Unified Approach.”
2. But, unlike this basic pledge by the international society, then G1 recently gave OECD a bum steer to fizzle it out—outdoor of IT, then now they have been meaning to overturn our agreement out of the blue by inflating its scope outside of IT. It’s wrong with its scope. It’s against our common sense, agreement to set this new rule into the other scopes. In fact, that meant these scopes not only could deal with consumer-facing businesses, but also might include such manufacturing businesses—(e.g.), automotive industry, consumer electronics industry, smartphone industry, semiconductor industry, or even cosmetic industry—(i.e.), over the whole industry based in the global supply chain. It’s wrong in the digital taxability to expand one scope into the other sectors as if this scope would integrate every consumer business provider or manufacturer into the consumer-facing business at all. That scope is so wrong; it’s too widely distorted by someone else. Ho, Uncle Sam! Did you do that? As a matter of fact, unless we’ll exclude these manufacturing businesses from this “Unified Approach,” that shall overturn the multilateral trade system as well as the international tax system on one’s own ways. In this regard, Korean civil society is now seriously concerned about the world war of the digital taxation that can beat both the system and join to pillage others’ tax revenue.
3. Hence, we the citizens register a strong protest with OECD over the one’s distorted “Unified Approach” to inflating this scope of digital taxation out of the IT business into the other businesses based in the manufacturing supply chain, in the same scope as this large consumer-facing business; on the grounds that tangible assets of the manufacturer’s own are appreciably different from intangible assets of the IT enterpriser’s transferability and erosivities with non-physical presence. So we make a review of the Secretariat Proposal for a “Unified Approach” under Pillar One, as the following comments: *See [CCEJ] Comments by Korean Civil society (En) Rev.2
[1] This statement was contributed by our true activist, Hochul Jung ([email protected]) and our peer reviewers, Prof. Hyochang Pang ([email protected]) and Prof. Hoon Park ([email protected]) in order to give our comments to the Task Force on the Digital Economy at OECD ([email protected]), to facilitate the G20 BEPS Project; and in the new order to take their BEPS Actions for the digital taxation of Information Technology Multinational Enterprises in the name of the “Google Tax.”
문의: 경제정책팀 (02-3673-2143)



위의 표에 나온 것처럼 한 단어만 바꾸면 많은 것들이 달라진다. 단순히 특정기업에 대한 특혜가 사라진다는 것만이 핵심은 아니다. 보험회사의 자산운용은 수많은 가입자들에게 영향을 줄 수 있다. 이 규정으로 인해 시장가치가 왜곡되고, 금융시장의 건전성이 흔들린다면 그 피해가 삼성에만 미친다고 할 수는 없다. 이러한 문제를 사전에 예방하고, 특혜 없는 공정한 시장 경제를 만들기 위해서라도 이 규정은 개정되어야 한다.
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