해외 자회사 업적평가에 있어서 세무관리의 역할

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During the business decision-making process, the tax environment is considered more important than the economic function of the foreign country, because the tax level can be very important environmental factor when the business performances, including parent company and foreign subsidiary, is evaluated. Global firms give a motive to CEO to make foreign subsidiary get better results. But during the process of funds transfer, the tax management which carries heavy tax burden can be negative factor that decreases the autonomy of CEO. Also, the point of autonomy of foreign subsidiary has a considerable relationship with matters of arbitrary decision by the CEO. Many parent companies have most of all parts of decision power. Therefore foreign subsidiaries are under control of parent company, which is shown by many researches. But by other research, we can see that the faster in going of foreign subsidiary and the longer time of in going, the more decision power are increased and the higher autonomy levels are given. And the higher autonomy levels are given, the higher foreign subsidiary's earning is achieved too. The delegation of decision power induces the high performance of CEO, which is also called virtuous circle. This means that autonomy level which is given to CEO is becoming the basic evaluation factors of foreign subsidiary. The efficient transfer of technical and managerial know-how from parent company, to foreign subsidiary, and foreign subsidiaries of global firms are significant factors of achievements in target earnings. It's, however, critically effected by international transfer pricing taxation and it can cause tax burden which is called international double taxation. In this case, the cost-sharing arrangement between parent company and foreign subsidiaries can be effective in managing taxation business. But in case of foreign subsidiary which has low level of autonomy, the cost-sharing arrangement increases the cost which is an effects of tax saving. But in the other hand, it has negative effect to CEO for foreign subsidiary. Eventually, to CEO who manages foreign subsidiary which has high level of autonomy, earning indicator is a significant factor for performance evaluation. Using new technology and tax saving money, cost-sharing arrangement will be a basic development source of foreign subsidiary. It, however, will take a long time to produce significant results. So, the CEO's performance has to be evaluated in the perspective of long time.