目次を引用しておこう。報告書の全体を一括してダウンロードできるが，これに加えて，各章を独立にダウンロードできたらさらに便利なのだが。
はじめに ·································································································· i
研究委員一覧 ··························································································· ⅵ
第１章 BEPS 勧告に基づく外国子会社合算税制の改革 ············ 青山 慶二 1
１．はじめに ·························································································· 1
２．BEPS 最終報告書（行動３）における勧告理念と改正法の対応 ······················ 2
３．改正法のその他留意点 ·········································································· 9
４．改正内容の評価と今後の課題 ·································································11
第２章 BEPS Action7 における PE の定義と PE の帰属利得：特に single
taxpayer approach vs. double taxpayer approach について
···················································································· 浅妻 章如 13
１．序論 ······························································································· 13
２．PE 課税概説：源泉・閾値・課税所得の範囲 ············································· 14
３．single taxpayer approach vs. double taxpayer approach ························ 20
４．まとめ ····························································································· 27
第３章 BEPS 問題に関連する最近の租税回避防止規定及び裁判例につい
ての覚書―ミスマッチ防止に関する個別規定及び一般的否認規定
に関する裁判例の考察を中心に―
···················································································· 渡辺 徹也 29
１．はじめに ··························································································· 29
２．ミスマッチ防止規定 ············································································· 30
３．租税回避否認法理 ················································································ 37
４．むすび ······························································································ 45
第４章 BEPS 後の一般国際税務及び移転価格税務の交錯 ······· 山川 博樹 47
１．問題意識 ···························································································· 47
２．ケーススタディの概要 ·········································································· 49
３．課税関係 ···························································································· 53
４．結語 ·································································································· 69
第５章 BEPS 後の中間持株会社に関する実務上のポイント
··································································· 原口 太一、上田 滋 71
１．はじめに ·························································································· 71
２．中間持株会社に関する一般的な現状の整理 ··············································· 71
３．中間持株会社の設立及び保有に関する一般的な税務上の論点······················· 73
４．今後の影響に関する考察 Ⅰ租税条約の改定 ············································· 85
５．今後の影響に関する考察 ⅡCFC 税制の改正 ············································ 88
６．おわりに ·························································································· 91
第６章 BEPS 後の日系企業の税務コントロール体制 ·············· 高嶋 健一 93
１．はじめに ·························································································· 93
２．日系企業に影響を与える BEPS 行動計画 ················································· 93
３．BEPS 行動計画により収集・管理すべきデータ・情報及び担当部署 ············· 101
４．BEPS 行動計画が税務マネジメント体制に与える影響とその対処方法 ·········· 110
５．結論 ······························································································ 120
第７章 紛争解決の防止・解決による確実性・透明性の向上
········································································· 岡田 至康 123
１．経緯 ······························································································ 123
２．BEPS プロジェクト主要行動計画上の課題（二重課税） ···························· 125
３．紛争の防止 ······················································································ 130
４．紛争の解決＝相互協議 ········································································· 135
５．紛争の解決＝仲裁等 ············································································ 137
