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조세심판원 질의회신 | 2012-06-28 | 부가가치세과-738 | 부가
Document Number

Value-added Tax (Value-Added Tax)

Items of Taxation

Addition

Journal

After concluding an export contract with a domestic trader who has entered into an export contract with a domestic trader who is located in a foreign country, it is to apply the zero-rate tax rate as it falls under Article 24 (1) 2 (d) of the Enforcement Decree of the Value-Added Tax Act to the case where a domestic trader transfers the goods processed by a domestic trader without compensation to a Chinese consignee, not to bring them into the country to a foreign trader designated by

Congress RESALS

After concluding an export contract with a domestic trader who has entered into an export contract with a domestic trader who is located in a foreign country, it is to apply the zero-rate tax rate as it falls under Article 24 (1) 2 (d) of the Enforcement Decree of the Value-Added Tax Act to the case where a domestic trader transfers the goods processed by a domestic trader without compensation to a Chinese consignee, not to bring them into the country to a foreign trader designated by

Related statutes

Article 11 of the Value-Added Tax Act

Main text

[Reference Materials Related to]

1. Factual basis

A. Questioner (hereinafter us) is a domestic entrepreneur who owns a manufacturing factory in China, and purchases all raw materials in Korea, and takes them out to China, and manufactures all products at 100% from China.

B. We enter into a contract with a domestic trader, deliver a product to a foreign importer who entered into an export contract with a domestic trader without bringing in the product of a Chinese local factory in Korea, and receive the price from a domestic trader in foreign currency.

2. Contents of questioning;

The domestic trader and the foreign importer designated by the domestic trader shall remove raw materials purchased in Korea under the supply contract with the domestic trader and supply them to the foreign importer, and the price shall be determined by the zero tax rate, if the domestic trader receives from the domestic trader

3. Materials on the contents of questioning;

○ Article 24 of the Enforcement Decree of the Value-Added Tax Act 【Scope of Exports】

(1) The export under Article 11 (1) 1 of the Act shall be as follows:

2. The following transactions are conducted, such as contract and receipt of consideration, at a domestic place of business:

(d) Export by consignment processing and trade method (referring to export by means of either exporting all or part of the raw materials to be processed (including manufacture, assembly, reproduction, and remodeling; hereinafter the same shall apply) in a foreign country to the other party to a transaction or supplying processed goods, etc. to a foreign country after procuring and processing them in a foreign country, and including cases where a transferee transfers the relevant goods to another business operator without bringing them into the Republic of Korea without compensation, without bringing them into the Republic of Korea, after shipping the raw materials into the foreign country to an overseas consignment processing