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Factors Affecting International Transfer Pricing of Multinational Enterprises in Korea (외국인투자기업의 국제이전가격 결정에 영향을 미치는 환경 및 기업요인)

  • Jun, Tae-Young;Byun, Yong-Hwan
    • Korean small business review
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    • v.31 no.2
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    • pp.85-102
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    • 2009
  • With the continued globalization of world markets, transfer pricing has become one of the dominant sources of controversy in international taxation. Transfer pricing is the process by which a multinational corporation calculates a price for goods and services that are transferred to affiliated entities. Consider a Korean electronic enterprise that buys supplies from its own subsidiary located in China. How much the Korean parent company pays its subsidiary will determine how much profit the Chinese unit reports in local taxes. If the parent company pays above normal market prices, it may appear to have a poor profit, even if the group as a whole shows a respectable profit margin. In this way, transfer prices impact the taxable income reported in each country in which the multinational enterprise operates. It's importance lies in that around 60% of international trade involves transactions between two related parts of multinationals, according to the OECD. Multinational enterprises (hereafter MEs) exert much effort into utilizing organizational advantages to make global investments. MEs wish to minimize their tax burden. So MEs spend a fortune on economists and accountants to justify transfer prices that suit their tax needs. On the contrary, local governments are not prepared to cope with MEs' powerful financial instruments. Tax authorities in each country wish to ensure that the tax base of any ME is divided fairly. Thus, both tax authorities and MEs have a vested interest in the way in which a transfer price is determined, and this is why MEs' international transfer prices are at the center of disputes concerned with taxation. Transfer pricing issues and practices are sometimes difficult to control for regulators because the tax administration does not have enough staffs with the knowledge and resources necessary to understand them. The authors examine transfer pricing practices to provide relevant resources useful in designing tax incentives and regulation schemes for policy makers. This study focuses on identifying the relevant business and environmental factors that could influence the international transfer pricing of MEs. In this perspective, we empirically investigate how the management perception of related variables influences their choice of international transfer pricing methods. We believe that this research is particularly useful in the design of tax policy. Because it can concentrate on a few selected factors in consideration of the limited budget of the tax administration with assistance of this research. Data is composed of questionnaire responses from foreign firms in Korea with investment balances exceeding one million dollars in the end of 2004. We mailed questionnaires to 861 managers in charge of the accounting departments of each company, resulting in 121 valid responses. Seventy six percent of the sample firms are classified as small and medium sized enterprises with assets below 100 billion Korean won. Reviewing transfer pricing methods, cost-based transfer pricing is most popular showing that 60 firms have adopted it. The market-based method is used by 31 firms, and 13 firms have reported the resale-pricing method. Regarding the nationalities of foreign investors, the Japanese and the Americans constitute most of the sample. Logistic regressions have been performed for statistical analysis. The dependent variable is binary in that whether the method of international transfer pricing is a market-based method or a cost-based method. This type of binary classification is founded on the belief that the market-based method is evaluated as the relatively objective way of pricing compared with the cost-based methods. Cost-based pricing is assumed to give mangers flexibility in transfer pricing decisions. Therefore, local regulatory agencies are thought to prefer market-based pricing over cost-based pricing. Independent variables are composed of eight factors such as corporate tax rate, tariffs, relations with local tax authorities, tax audit, equity ratios of local investors, volume of internal trade, sales volume, and product life cycle. The first four variables are included in the model because taxation lies in the center of transfer pricing disputes. So identifying the impact of these variables in Korean business environments is much needed. Equity ratio is included to represent the interest of local partners. Volume of internal trade was sometimes employed in previous research to check the pricing behavior of managers, so we have followed these footsteps in this paper. Product life cycle is used as a surrogate of competition in local markets. Control variables are firm size and nationality of foreign investors. Firm size is controlled using dummy variables in that whether or not the specific firm is small and medium sized. This is because some researchers report that big firms show different behaviors compared with small and medium sized firms in transfer pricing. The other control variable is also expressed in dummy variable showing if the entrepreneur is the American or not. That's because some prior studies conclude that the American management style is different in that they limit branch manger's freedom of decision. Reviewing the statistical results, we have found that managers prefer the cost-based method over the market-based method as the importance of corporate taxes and tariffs increase. This result means that managers need flexibility to lessen the tax burden when they feel taxes are important. They also prefer the cost-based method as the product life cycle matures, which means that they support subsidiaries in local market competition using cost-based transfer pricing. On the contrary, as the relationship with local tax authorities becomes more important, managers prefer the market-based method. That is because market-based pricing is a better way to maintain good relations with the tax officials. Other variables like tax audit, volume of internal transactions, sales volume, and local equity ratio have shown only insignificant influence. Additionally, we have replaced two tax variables(corporate taxes and tariffs) with the data showing top marginal tax rate and mean tariff rates of each country, and have performed another regression to find if we could get different results compared with the former one. As a consequence, we have found something different on the part of mean tariffs, that shows only an insignificant influence on the dependent variable. We guess that each company in the sample pays tariffs with a specific rate applied only for one's own company, which could be located far from mean tariff rates. Therefore we have concluded we need a more detailed data that shows the tariffs of each company if we want to check the role of this variable. Considering that the present paper has heavily relied on questionnaires, an effort to build a reliable data base is needed for enhancing the research reliability.

A Study on the Governance of U.S. Global Positioning System (미국 글로벌위성항법시스템(GPS)의 거버넌스에 관한 연구 - 한국형위성항법시스템 거버넌스를 위한 제언 -)

  • Jung, Yung-Jin
    • The Korean Journal of Air & Space Law and Policy
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    • v.35 no.3
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    • pp.127-150
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    • 2020
  • A Basic Plan for the Promotion of Space Development (hereinafter referred to as "basic plan"), which prescribes mid- and long-term policy objectives and basic direction-setting on space development every five years, is one of the matters to be deliberated by the National Space Committee. Confirmed February 2018 by the Committee, the 3rd Basic Plan has a unique matter, compared to the 2nd Basic Plan. It is to construct "Korean Positioning System(KPS)". Almost every country in the world including Korea has been relying on GPS. On the occasion of the shooting down of a Korean Air flight 007 by Soviet Russia, GPS Standard Positioning Service has been open to the world. Due to technical errors of GPS or conflict of interests between countries in international relations, however, the above Service can be interrupted at any time. Such cessation might bring extensive damage to the social, economic and security domains of every country. This is why some countries has been constructing an independent global or regional satellite navigation system: EU(Galileo), Russia(Glonass), India(NaVic), Japan(QZSS), and China(Beidou). So does South Korea. Once KPS is built, it is expected to make use of the system in various areas such as transportation, aviation, disaster, construction, defense, ocean, distribution, telecommunication, etc. For this, a pan-governmental governance is needed to be established. And this governance must be based on the law. Korea is richly experienced in developing and operating individually satellite itself, but it has little experience in the simultaneous development and operation of the satellites, ground, and users systems, such as KPS. Therefore we need to review overseas cases, in order to minimize trial and error. U.S. GPS is a classic example.

A Study on Recent Research Trend in New Product Development Using Keyword Network Analysis (키워드 네트워크 분석을 이용한 NPD 연구의 진화 및 연구동향)

  • Pyun, JeBum;Jeong, EuiBeom
    • Journal of Korea Society of Industrial Information Systems
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    • v.23 no.5
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    • pp.119-134
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    • 2018
  • Today, many firms face the environment of high uncertainty and severe competition due to the rapid technology development and the diverse needs of customers. In the business environment, one of the most important ways to gain sustainable competitive advantage and future growth engine is related to NPD (New Product Development), which is a very important issue for practice and academia. Thus, this study intends to provide new values to practitioners and researchers related to NPD by analyzing current research trends and future trends in NPD field. For this, we bibliometrically analyzed keyword networks which consist of keywords that were already published in the eminent journals from Scopus database to generate insights that have not been captured in the previous reviews on the topic. As a result, we could understand the extant research streams in NPD field, and suggest the changes of specific research topics based on the connected relationships among keywords over the time. In addition, we also foresaw the general future research trends in NPD field based on the keywords according to preferential attachment processes. Through this study, it was confirmed that NPD keyword network is a small world network that follows the distribution of power law and the growth of network is formed by link formation by keyword preferential attachment. In addition, through component analysis and centrality analysis, keywords such as Innovation, New product innovation, Risk management, Concurrent engineering, Research and development, and Product life cycle management are highly centralized in NPD keyword network. On the other hand, as a result of examining the change of preferential attachment of keywords over the time, we suggested the required new research direction including i) NPD collaboration with suppliers, ii) NPD considering market uncertainty, iii) NPD considering convergence with the other academic areas like technology management and knowledge management, iv) NPD from SME(Small and medium enterprises) perspective. The results of this study can be used to determine the research trends of NPD and the new research themes for interdisciplinary studies with other disciplines.

Improvement of Energy Density in Supercapacitor by Ion Doping Control for Energy Storage System (에너지 저장장치용 슈퍼커패시터 이온 도핑 제어를 통한 에너지 밀도 향상 연구)

  • Park, Byung-jun;Yoo, SeonMi;Yang, SeongEun;Han, SangChul;No, TaeMoo;Lee, Young Hee;Han, YoungHee
    • KEPCO Journal on Electric Power and Energy
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    • v.5 no.3
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    • pp.209-213
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    • 2019
  • Recently, demand for high energy density and long cycling stability of energy storage system has increased for application using with frequency regulation (F/R) in power grid. Supercapacitor have long lifetime and high charge and discharge rate, it is very adaptable to apply a frequency regulation in power grid. Supercapacitor can complement batteries to reduce the size and installation of batteries. Because their utilization in a system can potentially eliminate the need for short-term frequent replacement as required by batteries, hence, saving the resources invested in the upkeep of the whole system or extension of lifecycle of batteries in the long run of power grid. However, low energy density in supercapacitor is critical weakness to utilization for huge energy storage system of power grid. So, it is still far from being able to replace batteries and struggle in meeting the demand for a high energy density. But, today, LIC (Lithium Ion Capacitor) considered as an attractive structure to improve energy density much more than EDLC (Electric double layer capacitor) because LIC has high voltage range up to 3.8 V. But, many aspects of the electrochemical performance of LIC still need to be examined closely in order to apply for commercial use. In this study, in order to improve the capacitance of LIC related with energy density, we designed new method of pre-doping in anode electrode. The electrode in cathode were fabricated in dry room which has a relative humidity under 0.1% and constant electrode thickness over $100{\mu}m$ was manufactured for stable mechanical strength and anode doping. To minimize of contact resistance, fabricated electrode was conducted hot compression process from room temperature to $65^{\circ}C$. We designed various pre-doping method for LIC structure and analyzing the doping mechanism issues. Finally, we suggest new pre-doping method to improve the capacitance and electrochemical stability for LIC.

Distributional Characteristics, Population Structures and Fruition Dynamics of Korean Endemic plant, Prunus choreiana H. T. Im (한국특산 복사앵도나무(Prunus choreiana H. T. Im)의 분포특성, 개체군구조 및 결실동태)

  • Kim, Young-Chul;Chae, Hyun-Hee;Son, Sung-Won
    • Korean Journal of Environment and Ecology
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    • v.36 no.2
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    • pp.177-201
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    • 2022
  • Following the adoption of the global plant conservation strategies at the Conference of the Parties for Biodiversity Conservation, diligent actions to achieve each targets are actively carried out. In particular, the need for ecological conservation research to achieve targets 2 and 7 of GSPC-2020 has increased. The priority taxa to accomplish the objectives of GSPC-2020 are rare and endemic plants. In particular, endemic plants with limited distribution in specific regions are evaluated to face a high risk of extinction. To address the necessity to preserve endemic plants, we investigated the distribution of Prunus choreiana H. T. Im, a Korean endemic plant. After that, we examined the vegetational environment of the habitat of P. choreiana and evaluated its population structure. The productivity of its fruits and the effects of pollinators on fruit production were evaluated as well. The fruiting ratio was calculated based on the number of flowers produced. Lastly, we observed the annual growth characteristics of P. choreiana. The habitats of P. choreiana did not show a specific type of vegetation. All of them were located in a limestone area of Gangwon-do in the central Korean Peninsula and occupied a site where the coverage of the tree layer and the sub-tree layer was not high or did not exist. The population structure of P. choreiana contained a high proportion of mature plants capable of producing fruits and a low proportion of seedlings and Juvenile plants. We found that the production of fruits required pollinators and was affected by the performance of each plant. Although P. choreiana produces many flowers, only a maximum of 20% and only 2-6% on average bear fruits. These flowering characteristics may be due to pollinators' low abundance and activity during the flowering season (between mid-March and early April), suggesting that many flowers are needed to attract more pollinators. We rarely observed the re-establishment of seedlings in the population of P. choreiana. Despite that, we predict the population to persist owing to its long lifespan and periodic production of numerous fruits. However, if the tree layer and sub-tree layer in competing status with P. choreiana increase their crown density, they are expected to inhibit the growth of P. choreiana and affect the risk of its extinction. Therefore, the current changes in the vegetational environment of the habitats are expected to decrease the number and extent of P. choreiana in the long term. The results of this study may serve as primary and important data necessary for the achievement of GSPC-2020 objectives.

Structural features and Diffusion Patterns of Gartner Hype Cycle for Artificial Intelligence using Social Network analysis (인공지능 기술에 관한 가트너 하이프사이클의 네트워크 집단구조 특성 및 확산패턴에 관한 연구)

  • Shin, Sunah;Kang, Juyoung
    • Journal of Intelligence and Information Systems
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    • v.28 no.1
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    • pp.107-129
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    • 2022
  • It is important to preempt new technology because the technology competition is getting much tougher. Stakeholders conduct exploration activities continuously for new technology preoccupancy at the right time. Gartner's Hype Cycle has significant implications for stakeholders. The Hype Cycle is a expectation graph for new technologies which is combining the technology life cycle (S-curve) with the Hype Level. Stakeholders such as R&D investor, CTO(Chef of Technology Officer) and technical personnel are very interested in Gartner's Hype Cycle for new technologies. Because high expectation for new technologies can bring opportunities to maintain investment by securing the legitimacy of R&D investment. However, contrary to the high interest of the industry, the preceding researches faced with limitations aspect of empirical method and source data(news, academic papers, search traffic, patent etc.). In this study, we focused on two research questions. The first research question was 'Is there a difference in the characteristics of the network structure at each stage of the hype cycle?'. To confirm the first research question, the structural characteristics of each stage were confirmed through the component cohesion size. The second research question is 'Is there a pattern of diffusion at each stage of the hype cycle?'. This research question was to be solved through centralization index and network density. The centralization index is a concept of variance, and a higher centralization index means that a small number of nodes are centered in the network. Concentration of a small number of nodes means a star network structure. In the network structure, the star network structure is a centralized structure and shows better diffusion performance than a decentralized network (circle structure). Because the nodes which are the center of information transfer can judge useful information and deliver it to other nodes the fastest. So we confirmed the out-degree centralization index and in-degree centralization index for each stage. For this purpose, we confirmed the structural features of the community and the expectation diffusion patterns using Social Network Serice(SNS) data in 'Gartner Hype Cycle for Artificial Intelligence, 2021'. Twitter data for 30 technologies (excluding four technologies) listed in 'Gartner Hype Cycle for Artificial Intelligence, 2021' were analyzed. Analysis was performed using R program (4.1.1 ver) and Cyram Netminer. From October 31, 2021 to November 9, 2021, 6,766 tweets were searched through the Twitter API, and converting the relationship user's tweet(Source) and user's retweets (Target). As a result, 4,124 edgelists were analyzed. As a reult of the study, we confirmed the structural features and diffusion patterns through analyze the component cohesion size and degree centralization and density. Through this study, we confirmed that the groups of each stage increased number of components as time passed and the density decreased. Also 'Innovation Trigger' which is a group interested in new technologies as a early adopter in the innovation diffusion theory had high out-degree centralization index and the others had higher in-degree centralization index than out-degree. It can be inferred that 'Innovation Trigger' group has the biggest influence, and the diffusion will gradually slow down from the subsequent groups. In this study, network analysis was conducted using social network service data unlike methods of the precedent researches. This is significant in that it provided an idea to expand the method of analysis when analyzing Gartner's hype cycle in the future. In addition, the fact that the innovation diffusion theory was applied to the Gartner's hype cycle's stage in artificial intelligence can be evaluated positively because the Gartner hype cycle has been repeatedly discussed as a theoretical weakness. Also it is expected that this study will provide a new perspective on decision-making on technology investment to stakeholdes.