상속세의 국제적 이중과세에 관한 법적 고찰

Abstract

This article deals with the problems of double taxation by the inheritance taxes that may arise when an individual cross-border dies. In Korea, this topic can have more significant meaning compared to any other countries. OECD has made a model treaty aleady since 1960s. But todays one can rarely find a case of inheritance tax triety because of some minor points of the OECD model treaty. In this article the author tries to show where is the reason and how can it be solved. Each countries has a different criterum for the decision of tax-obligation ranges. Korea has not any inheritance tax treaty yet, however, in these global Era, Korea must more progressively come to grips with the problems of inheritance tax treaty. The author hopes this article may serve as a useful measure to the tax policy and taxplaning of the tax-payers.