과소자본세제

2013/04/08 16:57
과소자본세제
[insufficient capital tax system , 過少資本稅制]

[1] 특수관계가 있는 기업간에 있어 일정규모 이상의 차입금이자를 지급하는 경우, 이를 배당으로 간주하여 과세하는 제도를 말하는데, 국내 자회사를 지배하는 국외지배주주에 대한 차입금 또는 국외지배주주의 지급보증(담보의 제공 등 실질적으로 지급을 보증하는 경우 포함)에 의하여 제3자로부터 차입한 금액이 그 출자자본금의 3배(금융업은 6배)를 초과하는 경우에는 그 초과분에 대한 차입금이자를 손비처리하지 않고 배당과 기타사외유출로 각각 소득처분한다.

참조조문
국제조세조정에관한법률 제14조, 국제조세조정에관한법률 시행령 제24조~제28조
source :
[2]
특수 관계에 있는 기업 간의 과다한 차입금 이자를 배당으로 간주, 과세하는 제도. 현재 많은 국가들이 이자를 비용으로 인정, 손금으로 처리하는데 반해 배당은 비용으로 간주하지 않는다. 이에 따라 다국적 기업은 외국에 자회사를 설립할 때 자본금을 적게 하고 차입금을 늘려 진출국에서의 과세소득을 최소화하려는 경향이 있다. 과소자본세제는 이 같은 기업의 조세 회피를 규제하기 위한 것이다.
source :

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  79. Gris asphalt Hermes Kelly rush-hour sale 2025/04/27 11:59

    The Hermès Birkin bag stands as perhaps the most legendary symbol of
    luxury in the fashion world. Created for actress and singer Jane Birkin,
    this artisan-made handbag has evolved beyond its status
    as a mere luxury good to become a cultural phenomenon and prized possession that often increases in worth
    with passing years. With prices beginning at five
    figures and queues that can stretch years, the Birkin embodies the ultimate expression of exclusivity in premium fashion items.


    The History and Story

    The Birkin bag was created from a chance encounter in 1984 when Jane Birkin, sitting
    next to Hermès chief executive Jean-Louis Dumas on a
    flight from Paris to London, expressed frustration over not finding
    a leather weekend bag that met her requirements. Dumas
    immediately sketched a design on an airplane sickness bag—and the Birkin was conceived.

    Every Birkin is hand-made by a single skilled worker in France,
    requiring between 18 and 25 hours to finish. This meticulous artisanship, combined
    with the use of outstanding materials, accounts for both its considerable price
    tag and extraordinary durability.

    Sizing and Types

    The Birkin comes in several sizes, each denoted by the
    bag's width in centimeters:
    Birkin 25cm: The most popular size currently, excellent for everyday essentials while remaining elegant and
    compact
    Birkin 30cm: The standard size that combines practicality with elegance
    Birkin 35cm: A more spacious option preferred for its roominess as a day bag
    or for travel
    Birkin 40cm: Less common, designed for journeys or as a bold fashion statement

    Premium Materials and Craftsmanship

    Hermès obtains the most exceptional materials for its Birkin bags, with options including:
    Togo Calfskin: A long-lasting, pebbled leather
    with a slight sheen
    Clemence: A more flexible leather with a matte finish
    Epsom: A textured printed leather known for being lightweight and scratch-resistant
    Swift: A sleek leather with a subtle sheen
    Ostrich: Distinguished by its distinctive quill
    bumps
    Lizard: Displaying delicate, small scales in a distinctive pattern
    Crocodile and Alligator: The most luxurious and expensive options, showcasing larger
    scales and extraordinary luster

    The Most Desired Varieties

    Among enthusiasts and enthusiasts, certain Birkin editions
    stand out for their remarkable rarity and appeal:
    Himalaya Niloticus Crocodile Birkin: Often known as "the Holy Grail"
    of handbags, this bag showcases meticulously dyed crocodile skin that creates a tonal effect
    reminiscent of the Himalayan mountains. When decorated with diamond hardware, these bags have sold at auction for
    over $300,000.
    Diamond Birkins: Featuring hardware covered in diamonds, these embody the ultimate fusion of handbag craftsmanship and high jewelry.

    Sellier vs. Retourne: Birkins come in two main construction styles—the rigid
    Sellier with apparent outside stitching or the softer Retourne with
    internal stitching.
    Limited Editions: Unique collections like the Faubourg (resembling the façade of the Hermes flagship store) or
    Cargo (featuring additional external pockets) command significant premiums.


    HSS (Horseshoe Stamp): These bespoke Birkins allow clients to customize color combinations and
    hardware, making them distinctive collector's items.

    Color Range

    Hermès is celebrated for its extensive color palette,
    with certain hues reaching legendary status among collectors:
    Noir (Black): The traditional adaptable option
    Gold: A deep caramel tan that has become a characteristic Hermès color
    Blue Electric: A vibrant, saturated blue
    Rouge H: A intense Hermes red with brownish undertones
    Taupe: A sophisticated neutral gray-brown
    Craie: A delicate off-white shade
    Vert (various green shades): From deep forest to bright emerald tones

    The Financial Value

    While high-end fashion items typically decrease in worth after purchase, Birkins often grow more valuable—particularly rare colors, exotic
    materials, or limited editions. The pre-owned market for verified Birkins has expanded
    substantially, with some styles increasing in value 14% annually on average, outperforming traditional investment classes.


    Verification Concerns

    The Birkin's status as a symbol of luxury has
    unfortunately led to a significant market for counterfeits.
    Real Birkins feature perfect craftsmanship with:

    Exact, even stitching
    High-quality hardware with proper engravings
    A specific date stamp format
    Accompanying authenticity cards and proper packaging
    The distinctive Hermès saddle stitch

    Market Obtainability

    Purchasing a Birkin directly from an Hermès boutique remains challenging, as the bags are not displayed
    for regular purchase. Instead, they are typically provided to long-standing clients who have proven loyalty to the brand.

    This intentional scarcity has only strengthened the Birkin's mythical status and allure.


    Cultural Significance

    The Birkin has been highlighted prominently in popular culture, perhaps
    most memorably in an episode of "Sex and the City" where Samantha uses a client's name to skip the waiting list, and in many celebrity photos.
    It has become synonymous for supreme luxury and exclusivity,
    with collectors building entire "collections" of different sizes, colors, and materials.


    Conclusion

    More than just a bag, the Hermes Birkin embodies the
    convergence of masterful craftsmanship, classic design, and strategic exclusivity.
    Its continued popularity despite its substantial price point speaks to both its superiority and
    the strong allure of owning something truly remarkable.
    For fashion lovers and collectors alike, the Birkin remains the ultimate luxury item—a true icon that goes beyond fashion trends to achieve the status
    of artistic masterpiece.

    perm. |  mod/del. |  reply.
  80. where to buy super fakes 2025/04/27 14:32

    The Hermes Birkin handbag remains perhaps the most iconic symbol of high-end fashion in the world of fashion. Named after actress
    and singer Jane Birkin, this artisan-made purse has transcended
    its status as a mere luxury good to become a status symbol and prized possession that often appreciates in value with passing years.

    With prices commencing at five figures and reservation lists that
    can extend years, the Birkin symbolizes the pinnacle of exclusivity in premium fashion items.


    The Legacy and Story

    The Birkin bag was created from a serendipitous conversation in 1984 when Jane
    Birkin, seated next to Hermes chief executive Jean-Louis Dumas on a flight from Paris to London, expressed frustration over not finding
    a leather weekend bag that met her requirements. Dumas on the spot sketched a design on an airplane
    sickness bag—and the Birkin was conceived.

    Every Birkin is handcrafted by a single skilled worker in France, taking between 18 and 25 hours to finish.
    This painstaking craftsmanship, combined with the use of premium materials, accounts for both
    its considerable price tag and remarkable durability.


    Sizing and Varieties

    The Birkin comes in several sizes, each marked by the bag's
    width in centimeters:
    Birkin 25cm: The most sought-after size at present, excellent for everyday
    essentials while staying elegant and compact
    Birkin 30cm: The standard size that combines practicality with
    elegance
    Birkin 35cm: A larger option favored for its roominess as a day bag or for travel
    Birkin 40cm: More rare, designed for journeys or
    as a bold fashion statement

    Luxury Materials and Artisanship

    Hermès procures the most exceptional materials for its Birkin bags, with options including:

    Togo Calfskin: A long-lasting, pebbled leather
    with a slight sheen
    Clemence: A softer leather with a non-shiny finish
    Epsom: A grained printed leather recognized for being lightweight and scratch-resistant
    Swift: A refined leather with a natural sheen
    Ostrich: Characterized by its distinctive quill bumps
    Lizard: Featuring delicate, small scales in a special pattern
    Crocodile and Alligator: The most prestigious and expensive options,
    displaying larger scales and incredible luster

    The Most Coveted Versions

    Among collectors and enthusiasts, certain Birkin editions stand out
    for their extraordinary rarity and appeal:
    Himalaya Niloticus Crocodile Birkin: Often referred to as
    "the Holy Grail" of purses, this bag features meticulously dyed crocodile skin that creates a tonal effect reminiscent of the Himalayan mountains.

    When embellished with diamond hardware, these bags have sold at auction for over $300,000.

    Diamond Birkins: Showcasing hardware covered
    in diamonds, these represent the ultimate fusion of handbag artistry and high jewelry.

    Sellier vs. Retourne: Birkins come in two main construction styles—the
    firm Sellier with noticeable outside stitching
    or the more relaxed Retourne with internal stitching.

    Limited Editions: Special collections like the Faubourg (resembling the façade of the Hermès flagship store) or Cargo (featuring additional external pockets) fetch significant premiums.

    HSS (Horseshoe Stamp): These bespoke Birkins allow clients to personalize color combinations
    and hardware, making them one-of-a-kind collector's items.

    Color Range

    Hermes is renowned for its wide color palette, with certain hues reaching
    legendary status among collectors:
    Noir (Black): The traditional flexible option
    Gold: A rich caramel tan that has become a characteristic Hermes color
    Blue Electric: A vibrant, saturated blue
    Rouge H: A intense Hermès red with brownish undertones

    Taupe: A sophisticated neutral gray-brown
    Craie: A soft off-white shade
    Vert (various green shades): From deep forest to bright emerald tones

    The Investment Value

    While high-end fashion items typically depreciate after
    purchase, Birkins often grow more valuable—particularly rare colors, exotic materials, or limited editions.
    The resale market for certified Birkins has developed substantially,
    with some styles gaining worth 14% annually on average, outperforming traditional
    investment classes.

    Genuineness Concerns

    The Birkin's status as a prestigious accessory has unfortunately led to a considerable market for fakes.
    Real Birkins feature impeccable craftsmanship with:
    Accurate, even stitching
    High-quality hardware with proper engravings
    A specific date stamp format
    Accompanying authenticity cards and proper packaging
    The characteristic Hermes saddle stitch

    Market Obtainability

    Obtaining a Birkin directly from an Hermes boutique remains challenging, as the bags are not displayed for regular purchase.
    Instead, they are typically offered to long-standing clients who have demonstrated loyalty to the brand.
    This deliberate scarcity has only enhanced the Birkin's mythical status and appeal.


    Cultural Impact

    The Birkin has been showcased prominently in popular culture, perhaps most memorably in an episode of "Sex and the City" where Samantha
    uses a client's name to bypass the waiting list,
    and in many celebrity photos. It has become synonymous for ultimate luxury and exclusivity, with collectors building entire "collections" of different sizes, colors,
    and materials.

    Conclusion

    More than just a purse, the Hermès Birkin symbolizes the union of masterful
    craftsmanship, timeless design, and calculated exclusivity.
    Its persistent popularity despite its significant price point speaks to both its excellence and the powerful
    allure of owning something truly extraordinary. For fashion enthusiasts and collectors alike, the Birkin remains the ultimate luxury item—a true icon that
    rises above fashion trends to achieve the status of fashion masterwork.

    perm. |  mod/del. |  reply.
  81. Hermes Kelly gris asphalt resale offers 2025/04/27 17:48

    The Hermès Birkin bag remains perhaps the most iconic symbol
    of opulence in the world of fashion. Named after actress and singer Jane Birkin, this handcrafted bag has risen above its status as a mere accessory to become a fashion icon and valuable asset that often increases in worth as years go
    by. With prices commencing at five figures and reservation lists
    that can stretch years, the Birkin represents the pinnacle of rarity in high-end accessories.



    The History and Legacy

    The Birkin handbag was created from a fortuitous meeting in 1984 when Jane Birkin, seated next to Hermès chief executive Jean-Louis Dumas on a flight
    from Paris to London, complained about not finding a
    leather weekend bag that met her requirements. Dumas on the spot sketched a design on an airplane sickness bag—and the Birkin was created.


    Every Birkin is individually crafted by a single skilled worker in France, taking between 18 and 25 hours to finish.
    This detailed artisanship, combined with the use of outstanding materials, results in both its substantial price tag and incredible durability.



    Dimensions and Models

    The Birkin comes in multiple sizes, each indicated
    by the bag's width in centimeters:
    Birkin 25cm: The best-selling size at present, excellent for
    everyday essentials while remaining elegant and compact

    Birkin 30cm: The standard size that combines practicality with elegance
    Birkin 35cm: A larger option favored for its space as a day bag or for travel

    Birkin 40cm: More rare, designed for journeys or as a bold fashion statement

    Luxury Materials and Artisanship

    Hermès sources the most exceptional materials for its Birkin bags, with options including:

    Togo Calfskin: A sturdy, pebbled leather with a slight sheen
    Clemence: A softer leather with a matte finish
    Epsom: A grained printed leather celebrated for being lightweight and scratch-resistant

    Swift: A smooth leather with a natural sheen
    Ostrich: Characterized by its unique quill bumps

    Lizard: Featuring delicate, small scales in a unique pattern
    Crocodile and Alligator: The most luxurious and high-priced options,
    displaying larger scales and extraordinary luster

    The Most Desired Editions

    Among enthusiasts and enthusiasts, certain Birkin editions stand out for their extraordinary rarity and appeal:

    Himalaya Niloticus Crocodile Birkin: Often called "the Holy Grail" of luxury bags, this bag features meticulously dyed crocodile skin that creates a gradation reminiscent
    of the Himalayan mountains. When adorned with diamond hardware, these
    bags have sold at sale for over $300,000.
    Diamond Birkins: Featuring hardware covered in diamonds, these embody
    the highest fusion of handbag craftsmanship and high jewelry.

    Sellier vs. Retourne: Birkins come in two principal construction styles—the firm Sellier with apparent outside stitching or
    the more supple Retourne with internal stitching.
    Limited Editions: Exclusive collections like the Faubourg (resembling the façade of
    the Hermès flagship store) or Cargo (featuring additional external
    pockets) demand significant premiums.
    HSS (Horseshoe Stamp): These special-order Birkins allow clients to customize color
    combinations and hardware, making them distinctive
    collector's items.

    Color Palette

    Hermes is renowned for its wide color palette, with certain hues achieving legendary status among collectors:
    Noir (Black): The timeless adaptable option
    Gold: A warm caramel tan that has become a signature Hermes color
    Blue Electric: A vibrant, saturated blue
    Rouge H: A intense Hermès red with brownish undertones
    Taupe: A refined neutral gray-brown
    Craie: A soft off-white shade
    Vert (various green shades): From deep forest to bright emerald tones

    The Monetary Value

    While high-end fashion items typically decrease in worth after purchase, Birkins
    often grow more valuable—particularly rare colors, exotic materials,
    or limited editions. The resale market for authenticated Birkins has developed substantially, with some styles increasing in value
    14% annually on average, surpassing traditional investment classes.


    Authentication Concerns

    The Birkin's status as a luxury icon has unfortunately led to a considerable market for
    counterfeits. Genuine Birkins feature perfect craftsmanship with:
    Exact, even stitching
    High-quality hardware with proper engravings
    A specific date stamp format
    Matching authenticity cards and proper packaging
    The unique Hermès saddle stitch

    Market Accessibility

    Purchasing a Birkin directly from an Hermes boutique remains challenging, as the bags are not
    exhibited for regular purchase. Instead, they are typically provided to established clients who have shown loyalty
    to the brand. This planned scarcity has only enhanced the Birkin's mythical
    status and allure.

    Cultural Impact

    The Birkin has been highlighted prominently in media, perhaps most memorably in an episode of "Sex and the City" where
    Samantha uses a client's name to avoid the waiting list, and in countless celebrity photos.
    It has become synonymous for supreme luxury and exclusivity, with collectors developing entire
    "collections" of different sizes, colors, and materials.


    Summary

    More than just a bag, the Hermes Birkin represents the union of masterful expertise, enduring design, and deliberate exclusivity.
    Its ongoing popularity despite its substantial price point speaks to both its excellence
    and the strong allure of owning something truly exceptional.
    For fashion aficionados and collectors alike, the Birkin remains the ultimate statement piece—a true classic that
    rises above fashion trends to achieve the status of artistic masterpiece.

    perm. |  mod/del. |  reply.
  82. Truco Services Reliable year-round landscaping company Utah 2025/04/27 20:19

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    perm. |  mod/del. |  reply.
  83. Gris asphalt Kelly Hermes VIP access 2025/04/30 07:43

    The Hermès Birkin handbag remains perhaps the most celebrated symbol of opulence in the fashion world.
    Created for actress and singer Jane Birkin, this artisan-made purse has transcended its
    status as a mere luxury good to become a cultural phenomenon and prized
    possession that often grows more valuable
    as years go by. With prices starting from five
    figures and queues that can span years, the Birkin embodies
    the height of rarity in luxury goods.

    The Legacy and Legacy

    The Birkin bag was conceived from a serendipitous conversation in 1984 when Jane
    Birkin, sitting next to Hermes chief executive Jean-Louis Dumas on a flight from Paris to London, expressed frustration over not finding a leather weekend bag
    that met her requirements. Dumas promptly sketched a design on an airplane sickness bag—and the
    Birkin was conceived.
    Every Birkin is individually crafted by a single artisan in France, taking between 18 and 25 hours
    to produce. This meticulous artisanship, combined with the use
    of premium materials, results in both its hefty price tag and remarkable durability.


    Dimensions and Varieties

    The Birkin comes in various sizes, each indicated by the bag's width in centimeters:

    Birkin 25cm: The most popular size currently, perfect for everyday essentials while staying elegant and compact

    Birkin 30cm: The standard size that merges practicality with elegance
    Birkin 35cm: A more spacious option favored for its roominess as a day bag
    or for travel
    Birkin 40cm: Not as popular, designed for travel or as a
    statement piece

    Luxury Materials and Artisanship

    Hermès sources the finest materials for its Birkin bags, with options including:

    Togo Calfskin: A durable, pebbled leather with a subtle
    sheen
    Clemence: A more supple leather with a flat finish
    Epsom: A structured printed leather recognized for being
    lightweight and scratch-resistant
    Swift: A refined leather with a natural sheen
    Ostrich: Characterized by its characteristic quill bumps
    Lizard: Displaying delicate, small scales in a unique pattern
    Crocodile and Alligator: The most exclusive and high-priced options, featuring larger scales and
    extraordinary luster

    The Most Coveted Editions

    Among collectors and enthusiasts, certain Birkin editions stand out for their remarkable rarity and
    appeal:
    Himalaya Niloticus Crocodile Birkin: Often called "the Holy Grail" of
    handbags, this bag features meticulously dyed crocodile skin that creates a gradient reminiscent of the Himalayan mountains.
    When embellished with diamond hardware, these
    bags have sold at sale for over $300,000.
    Diamond Birkins: Boasting hardware encrusted with diamonds, these symbolize the
    ultimate fusion of handbag craftsmanship and high jewelry.


    Sellier vs. Retourne: Birkins come in two principal construction styles—the firm
    Sellier with noticeable outside stitching or the softer Retourne with internal stitching.

    Limited Editions: Unique collections like the Faubourg
    (resembling the façade of the Hermès flagship store)
    or Cargo (featuring additional external pockets) fetch significant premiums.


    HSS (Horseshoe Stamp): These bespoke Birkins allow clients to tailor color combinations and hardware,
    making them distinctive collector's items.

    Color Palette

    Hermes is renowned for its broad color palette, with certain hues reaching legendary
    status among collectors:
    Noir (Black): The traditional versatile option
    Gold: A rich caramel tan that has become a signature Hermès color
    Blue Electric: A bright, saturated blue
    Rouge H: A rich Hermès red with brownish undertones
    Taupe: A refined neutral gray-brown
    Craie: A creamy off-white shade
    Vert (various green shades): From deep forest to bright emerald
    tones

    The Monetary Value

    While luxury fashion items typically depreciate after purchase,
    Birkins often increase in value—particularly rare
    colors, exotic materials, or limited editions. The resale market for
    authenticated Birkins has developed substantially,
    with some styles gaining worth 14% annually on average,
    surpassing traditional investment classes.

    Authentication Concerns

    The Birkin's status as a luxury icon has unfortunately led to a significant market for counterfeits.
    Authentic Birkins feature flawless craftsmanship with:

    Accurate, even stitching
    Superior hardware with proper engravings
    A exact date stamp format
    Matching authenticity cards and proper packaging
    The distinctive Hermes saddle stitch

    Market Obtainability

    Acquiring a Birkin directly from an Hermes boutique remains difficult,
    as the bags are not displayed for regular purchase.

    Instead, they are typically provided to long-standing clients who
    have proven loyalty to the brand. This deliberate scarcity has only enhanced the Birkin's iconic position and allure.


    Cultural Influence

    The Birkin has been featured prominently in popular culture, perhaps most memorably in an episode of "Sex and the City" where Samantha uses a client's
    name to avoid the waiting list, and in numerous celebrity photos.
    It has become a symbol for supreme luxury and exclusivity, with collectors developing entire "collections" of different sizes, colors,
    and materials.

    Final Thoughts

    More than just a purse, the Hermès Birkin symbolizes the meeting of
    masterful craftsmanship, classic design, and strategic exclusivity.
    Its persistent popularity despite its significant
    price point speaks to both its excellence and the powerful allure of owning something truly extraordinary.
    For fashion lovers and collectors alike, the Birkin remains the supreme luxury item—a true classic that transcends fashion trends
    to achieve the status of fashion masterwork.

    perm. |  mod/del. |  reply.
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