Issues concerning Income Taxation of Corporations associated with Risk Shifting-Focus on Reinsurance Transactions
Project/Area Number |
24530038
|
Research Category |
Grant-in-Aid for Scientific Research (C)
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Allocation Type | Multi-year Fund |
Section | 一般 |
Research Field |
Public law
|
Research Institution | Kansai University |
Principal Investigator |
TSUJI Mie 関西大学, 商学部, 准教授 (00440917)
|
Project Period (FY) |
2012-04-01 – 2015-03-31
|
Project Status |
Completed (Fiscal Year 2014)
|
Budget Amount *help |
¥3,250,000 (Direct Cost: ¥2,500,000、Indirect Cost: ¥750,000)
Fiscal Year 2014: ¥1,040,000 (Direct Cost: ¥800,000、Indirect Cost: ¥240,000)
Fiscal Year 2013: ¥1,040,000 (Direct Cost: ¥800,000、Indirect Cost: ¥240,000)
Fiscal Year 2012: ¥1,170,000 (Direct Cost: ¥900,000、Indirect Cost: ¥270,000)
|
Keywords | 再保険 / キャプティブ保険 / 国際課税 / 移転価格 / 保険 / 連邦消費税 / 租税法 / 所得課税 |
Outline of Final Research Achievements |
In my research, I have been focusing on the issues which arise between reinsurance transactions and income taxation of corporations with the aim of finding the appropriate tax system for reinsurance transactions. I focus on (1) reinsurance by insurance companies and (2) captive insurance by non-insurance companies. Concerning (1), I researched the excise tax on reinsurance premiums for foreign insurance companies in the United States. Concerning (2), I analyzed the possibility of deductions for insurance premiums (i.e. economic substance of transactions) and the validity of the amount of the premium (i.e. transfer pricing). For the former, I analyzed the latest tax case in the United States. For the latter, I analyzed tax cases in the Netherlands and the United Kingdom and then compared the Dutch transfer pricing regime with the new Japanese regime.
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Report
(4 results)
Research Products
(7 results)