국제적 보험사업에 따른 귀속소득의 결정

OECD published “2010 Report on the Attribution of Profits to Permanent Establishments” by obtaining approval from Committee on Fiscal Affairs on June 22, 2010 and obtaining publication approval from the Council on July 22, 2010. This report details international taxation of insurance business sector in Special Considerations for Applying the Authorised OECD Approach to Permanent Establishments of Insurance Companies in the Part IV. This report has significant implications in this business because no other guidelines have not been presented internationally on transfer pricing in this field except this. It means that this guideline will be applied as the only instructions on transfer pricing of the insurance companies which operate internationally in the future. With the coming into effect of International Fiscal Reporting System (IFRS), the guideline will have considerable impact in the international taxation of the insurance companies. This article was intended to introduce the recent trends in the attribution of income to the international insurance business, and is reviewed the attitude of the OECD report on the taxation of reinsurance business sector, a special type of insurance additionally.