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第１章

次我が国機械関係企業のアジア事業展開の現状·······················································

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１．我が国機械関係企業のアジアにおける事業展開と戦略・組織の現状····························

1(1) 日本企業による海外事業展開の動向とアジアの位置付け········································

1(2) 日本機械企業によるアジア事業展開の戦略・組織・バリューチェーン······················

3(3) 日本機械企業におけるアジア地域統括会社··························································

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２．アジア事業展開上の国際税務問題·········································································

6３．アジア事業展開とグローバル税務マネジメント······················································· 18(1) グローバル税務マネジメントの概要··································································· 18(2) アジア事業展開におけるグローバル税務マネジメント上の留意点···························· 21第２章

アジア展開に係る最近の国際税務問題と対応策···················································· 25

第１節

地域統括会社に係る国際税務上の論点································································ 25

１．アジア地域統括会社の活用による税務上のメリット················································· 25(1) アジア地域統括会社の活用によるアジア各国の税務上のメリット···························· 25(2) アジア地域統括会社の活用による日本の税務上のメリット····································· 26(3) 来料加工取引と本邦タックスヘイブン税制·························································· 38

第２節

我が国機械企業による中国事業展開上の国際税務問題··········································· 44

１．租税条約上の恩典適用時の「受益者」認定····························································· 44(1) 中国投資時の持株会社設立国の選定··································································· 44(2) 601 号通達による「受益者」認定 ······································································ 45(3) 留意点·········································································································· 46
２．非居住企業に対する持分譲渡所得に係る課税強化···················································· 47

(1) 概要············································································································· 47(2) 持分譲渡益の計算··························································································· 47(3) 間接持分譲渡································································································· 48(4) 留意点·········································································································· 49
３．企業再編（Ｍ＆Ａ）取引····················································································· 49(1) 概要及び論点································································································· 49(2) 企業再編に係る課税関係·················································································· 52(3) 留意点·········································································································· 52
４．租税条約の解釈に関する指針··············································································· 53(1) 概要············································································································· 53(2) 受動的所得に関する論点·················································································· 54(3) 恒久的施設(PE)に係る論点··············································································· 55(4) 出向契約に係る論点························································································ 57
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参考：

留意点 ········································································································ 58

韓国多国籍企業のグローバル・タックスマネジメントの現状······························· 61

１．韓国多国籍企業におけるグローバル・タックスマネジメントの現状···························· 61(1) 外部専門家の利用··························································································· 62(2) 移転価格税制への注力····················································································· 62
２．韓国多国籍企業のグローバル・タックスマネジメントにおける税務戦略、税務組織、情報インフラ、社内における税務の位置付け等········································ 63(1) 組織体制······································································································· 63(2) 管理体制······································································································· 64(3) 評価制度······································································································· 65