• 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.

• Korean small business review
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• v.32 no.2
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• pp.209-223
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• 2010

Korea's business is composed of a few large-sized enterprises (which can be abbreviated as LSE) and a majority of small-sized enterprises (SSE). Although there has been a growing recognition of the need for the development of medium-sized enterprises (MSE) which can serve as a link between SSE and LSE, as yet there has not yet been a consensus on the definition, characteristics and the function of the MSE in Korea. Nowadays, the world is being globalized, and Japan and China are in competition to ne a great economic power. While East Asia is experiencing rapid changes, promoting MSE which can secure flexibility and efficiency through covering up the limitation of LSE and SSE is needed in order to respond the global market which is being specialized. The features of MSE in Japan can be listed as follows. First, the MSE in Japan is developing the company through getting into niche markets which are hard for major companies to enter rather than developing markets in order to compete against major companies directly. While MSEs are endeavoring to build the business firmly in the domestic market, they can possess special and competitive technical skills through trials and errors; so that they can get a chance develop their business through independent business system rather than putting their effort to compete against major companies. Second, from the MSEs with competitive edge in the market, there are many contributions to the national exportation. Those MSEs produce in domestic and maintain the quality of high price products which need cutting-edge technology, while they relocate the low and middle priced goods to the country where manufacturing costs are low, so that they can maintain the price competitiveness. Third, the industrial structure in Japan is formed from dual structure between major companies and small sized companies. In other words, in Japan's industrial structure which are composed of subcontract structure, this dual structure has taken a major role of small sized companies' growth and manufacturing businesses' international competitive power. Forth, MSE in Japan adopt a strategy of putting their value on qualitative scale growth rather than quantitative scale growth. In this paper, the case of Japanese MSE is analyzed. Along with its long history of Industrialization, Japan has a corporate environment where the SSEs can develop as a MSE and later a LSE through a full-support system. Among its SSEs, there are a number of world class corporations equipped with a large domestic market, win-win cooperation with the LSEs and an independent technology development. It can also be observed that these SSEs develop into MSEs with sustainable growth potentials. This study will focus on the condition under which the MSEs of Japan have been developed, and how they have survived the competition between SSEs and LSEs. Through this study, this paper attempts to offer solutions to Korea's polarization between the SSE and LSE, while providing the basis for SSEs revitalization. In general, if both extremities phenomenon deepen between LSE and SSE, there are possible fears of occurring disutility in national economy by the monopolization of LSE. For that reason, enterprise group, which can make SSE or MSE compete LSE in some area and ease the monopoly and oligopoly problem, is needed. This awareness has been shared for ages long. Nevertheless, there is no legal definition for MSE in Japan, and there is no definition about the enterprise size or unified view of MSE between scholars, but it is defined differently by each of academical person or research institution and study meeting. For that reason, this paper will organize the definition of MSE in Japan, and then will propose the characteristics of the background which has made MSE secure competitiveness and sustainable growth in global market. This study focus on that because through this process, the positive change to the awareness of MSE can be proposed in Korea and to seek the policy direction for building institutional framework which can make SSE become MES. Through this way, the fundamentals for SSE to become MSE can be managed and some appropriate suggestions which will be able to make MSE enter the global market in the future can also be proposed. Due to these facts, this study is very important and well timed task. In a sense of this way, this study will examine the definition and role of MSE in Japan. after this examination, this study will deal with the status, special feature, and promotion policy for MSE. Through this analysis of MSE in Japan, the foundation which be able to set the desirable role model for MSE in Korea can be proposed. Also, the political implication which is needed to push ahead to contribute to creating employment and economic growth through sustainable growth of MSEs in economic system of Korea can be offered through this study. It has been found that Japan's MSE functions as an indispensable link among various industrial structures by holding a significant position in employment rate, production and value added. Although the MSEs took up less than 1% of the entire number of businesses with 2700 manufacturing firms and 7000 non-manufacturing firms, its employment ratios are about 15%, while taking about 25% of the manufacturing industry's exports. In industries such as machinery and electronics which is considered Japan's major industry, the MSEs showed a higher than average ratio of manufacturing exports and employment rate. It can be analyzed that behind Japan's advantageous industries, close and deeply knit MSEs exist. Although there are no clearly stated policies geared towards the MSEs by the Japanese government, various political measures exist such as the R&D Project and the inducement of cooperation between enterprises which gives room for MSEs to participate in the SSE policies. In relation to these findings, the following practical measures can be considered in order to revitalize Korea's MSEs: First, there is a need for a legal definition of MSE and the incentives to provide legal support for its growth. Second, if a law to support the MSEs is established, it could provide a powerful inducement for the SSE to grow as a MSE, rather than stay as a SSE. Third, there is a need for a strategy of MSEs to establish a stable base in the domestic market and then advance to the global market with the accumulated trial and error and competitiveness. Fourth, the SSE themselves need the spirit of entrepreneurship in order to make the leap to a MSE. Because if nothing is to be changed about the system on the firms that grew, and the parts of the past custom was left to be managed alone, confusion and absence of management can take place. No matter how much tax favors the government will give and no matter how much incentive there could be through the policies, there are limits for industries to higher the ability to propagate. And because of that it is a period where industries need their own innovative skills to reform their firms.

• KOREAN JOURNAL OF CROP SCIENCE
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• v.3
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• pp.1-40
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• 1965

To measure variations in some of the important agronomic characteristics of rice varieties under shifting of seedling dates, this study has been carried out at the Paddy Crop Division of Crop Experiment Station(then Agricultural Experiment Station) in Suwon for the period of three years 1958 to 1960. The varieties used in this study were Kwansan, Suwon ＃82, Mojo, Paltal and Chokwang, which have the different agronomic characteristics such as earliness and plant type. Seeds of each variety were sown at 14 different dates in 10-day interval starting on March 2. The seedlings were grown on seed bed for 30, 40, 50, 60, 70 and 80 days, respectively. The results of this study are as follows: A. Heading dates. 1. As the seeding date was delayed, the heading dates was almost proportionally delayed. The degree of delay was higher in early varieties and lower in late varieties and the longer the seedling stage, the more delayed the heading date. 2. Number of days to heading was proportionally lessened as seeding was delayed in all the varieties but the magnitude varied depending upon variety. In other words, the required period for heading in case of late planting was much shortened in late variety compared with early one. Within a variety, the number of days to heading was less shortened as the seedling stage was prolonged. Early variety reached earlier than late variety to the marginal date for the maximum shortening of days to heading and the longer the seeding stage, the limitted date came earlier. There was a certain limit in seeding date for shortening of days to heading as seeding was delayed, and days to heading were rather prolonged due to cold weather when seeded later than that date. 3. In linear regression equation, Y=a+bx obtained from the seeding dates and the number of days to heading, the coefficient b(shortening rate of days to heading) was closely correlated with the average number of days to heading. That is, the period from seeding to heading was more shortened in late variety than early one as seeding was delayed. 4. To the extent that the seedling stage is not so long and there is a linear relationship between delay of seeding and shortening of days to heading, it might be possible to predict heading date of a rice variety to be sown any date by using the linear regression obtained from variation of heading dates under the various seeding dates of the same variety. 5. It was found out that there was a close correlation between the numbers of days to heading in ordinary culture and the other ones. When a rice variety was planted during the period from the late part of March to the middle of June and the seedling ages were within 30 to 50 days, it could be possible to estimate heading date of the variety under late or early culture with the related data of ordinary culture. B. Maturing date. 6. Within (he marginal date for maturation of rice variety, maturing date was proportionally delayed as heading was delayed. Of course, the degree of delay depended upon varieties and seedling ages. The average air temperature (Y) during the ripening period of rice variety was getting lower as the heading date. (X) was delayed. Though there was a difference among varieties, in general, a linear regression equation(y=25.53-0.182X) could be obtained as far as heading date were within August 1 to September 13. 7. Depending upon earliness of a rice variety, the average air temperature during the ripening period were greatly different. Early variety underwent under 28$^{\circ}C$ in maximum while late variety matured under as low as 22$^{\circ}C$. 8. There was a highly significant correlation between the average air temperature (X) during the ripening period, and number of day (Y) for the maturation. And the relationship could be expressed as y=82.30-1.55X. When the average air temperature during the period was within the range of 18$^{\circ}C$ to 28$^{\circ}C$, the ripening period was shortened by 1.55 days with increase of 1$^{\circ}C$. Considering varieties, Kwansan was the highest in shortening the maturing period by 2.24 days and Suwon ＃82 was the lowest showing 0.78 days. It is certain that ripening of rice variety is accelerated at Suwon as the average air temperature increases within the range of 18$^{\circ}C$ to 28$^{\circ}C$. 9. Between number of days to heading (X) related to seeding dates and the accumulated average air temperature (Y) during the ripening period, a positive correlation was obtained. However, there was a little difference in the accumulated average air temperature during the ripening period even seeding dates were shifted to a certain extent. C. Culm- and ear-lengths. 10. In general all the varieties didn't show much variation in their culm-lengths in case of relatively early seeding but they trended to decrease the lengths as seeding was delayed. The magnitude of decreasing varied from young seedlings to old ones. Young seedlings which were seeded during May 21 to June 10 didn't decrease their culm-lengths, while seedlings old as 80 days decreased the length though under ordinary culture. 11. Variation in ear-length of rice varieties show the same trend as the culm-length subjected to the different seeding dates. When rice seedlings aged from 30 to 40 days, the ear-length remained constant but rice plants older than 40 days obviously decreased their ear-lengths. D. Number of panicles per hill. 12. The number of panicles per hill decreased up to a certain dates as seeding was delayed and then again increased the panicles due to the development of numerous tillers at the upper internodes. The seeding date to reach to the least number of panicles of rice variety depended upon the seedling ages. Thirty- to 40-day seedlings which were seeded during May 31 to June 10 developed the lowest number of panicles and 70- to 80-day seedlings sown for the period from April 11 to April 21 reached already to the minimum number of panicles. E. Number of rachillae. 13. To a certain seeding date, the number of rachillae didn't show any variation due to delay of seeding but it decreased remarkably when seeded later than the marginal date. 14. Variation in number of rachillae depended upon seedling ages. For example, 30- to 40-day old seedlings which, were originally seeded after May 31 started to decrease the rachillae. On the other hand, 80-day old seedlings which, were seeded on May 1 showed a tendency to decrease rachillae and the rice plant sown on May 31 could develop narrowly 3 or 4 panicles. F. Defective grain and 1.000-grain weights. 15. Under delay of the seeding dates, weight of the defective grains gradually increased till a certain date and then suddenly increased. These relationships could be expressed with two different linear regressions. 16. If it was assumed that the marginal date for ripening was the cross point of these two lines, the date seemed. closely related with seedling ages. The date was June 10- in 30- to 40-day old seedlings but that of 70- to 80-day old seedlings was May 1. Accordingly, the marginal date for ripening was getting earlier as the seedling stage was prolonged. 17. The 1.000-grain weight in ordinary culture was the heaviest and it decreased in both early and late cultures. G. Straw and rough rice weights. 18. Regardless of earliness of variety, rice plants under early culture which were seeded before March 22 or April 1 did not show much variation in straw weight due to seedling ages but in ordinary culture it gradually decreased and the degree was became greater in late culture. 19. Relationship between seeding dates (X) and grain weight related to varieties and seedling ages, could be expressed as a parabola analogous to a line (Y=77.28-7.44X$_1$-1.00lX$_2$). That is, grain yield didn't vary in early culture but it started to decrease when seeded later than a certain date, as seeding was delayed. The variation was much greater in cases of late planting and prolongation of seedling age. 20. Generally speaking, the relationship between grain yield (Y) and number of days to heading (X) was described with linear regression. However, the early varieties were the highest yielders within the range of 60 to 110, days to heading but the late variety greatly decreased its yield since it grows normally only under late culture. The grain yield, on the whole, didn't increase as number of days to heading exceeded more than 140 days.

• MISULJARYO - National Museum of Korea Art Journal
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• v.96
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• pp.18-53
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• 2019

The paintings Gyeongpodae Pavilion and Chongseokjeong Pavilion were recently donated to the National Museum of Korea and unveiled to the public for the first time at the 2019 special exhibition "Through the Eyes of Joseon Painters: Real Scenery Landscapes of Korea." These two paintings carry significant implications for understanding Joseon art history. Because the fact that they were components of a folding screen produced after a sightseeing tour of the Gwandong regions in 1557 has led to a broadening of our understanding of sixteenth-century landscape painting. This paper explores the art historical meanings of Gyeongpodae Pavilion and Chongseokjeong Pavilion by examining the contents in the two paintings, dating them, analyzing their stylistic characteristics, and comparing them with other works. The production background of Gyeongpodae Pavilion and Chongseokjeong Pavilion can be found in the colophon of Chongseokjeong Pavilion. According to this writing, Sangsanilro, who is presumed to be Park Chung-gan (?-1601) in this paper, and Hong Yeon(?~?) went sightseeing around Geumgangsan Mountain (or Pungaksan Mountain) and the Gwandong region in the spring of 1557, wrote a travelogue, and after some time produced a folding screen depicting several famous scenic spots that they visited. Hong Yeon, whose courtesy name was Deokwon, passed the special civil examination in 1551 and has a record of being active until 1584. Park Chung-gan, whose pen name was Namae, reported the treason of Jeong Yeo-rip in 1589. In recognition of this meritorious deed, he was promoted to the position of Deputy Minister of the Ministry of Punishments, rewarded with the title of first-grade pyeongnan gongsin(meritorious subject who resolved difficulties), and raised to Lord of Sangsan. Based on the colophon to Chongseokjeong Pavilion, I suggest that the two paintings Gyeongpodae Pavilion and Chongseokjeong Pavilion were painted in the late sixteenth century, more specifically after 1557 when Park Chung-gan and Hong Yeon went on their sightseeing trip and after 1571 when Park, who wrote the colophon, was in his 50s or over. The painting style used in depicting the landscapes corresponds to that of the late sixteenth century. The colophon further states that Gyeongpodae Pavilion and Chongseokjeong Pavilion were two paintings of a folding screen. Chongseokjeong Pavilion with its colophon is thought to have been the final panel of this screen. The composition of Gyeongpodae Pavilion recalls the onesided three-layered composition often used in early Joseon landscape paintings in the style of An Gyeon. However, unlike such landscape paintings in the An Gyeon style, Gyeongpodae Pavilion positions and depicts the scenery in a realistic manner. Moreover, diverse perspectives, including a diagonal bird's-eye perspective and frontal perspective, are employed in Gyeongpodae Pavilion to effectively depict the relations among several natural features and the characteristics of the real scenery around Gyeongpodae Pavilion. The shapes of the mountains and the use of moss dots can be also found in Welcoming an Imperial Edict from China and Chinese Envoys at Uisungwan Lodge painted in 1557 and currently housed in the Kyujanggak Institute for Korean Studies at Seoul National University. Furthermore, the application of "cloud-head" texture strokes as well as the texture strokes with short lines and dots used in paintings in the An Gyeon style are transformed into a sense of realism. Compared to the composition of Gyeongpodae Pavilion, which recalls that of traditional Joseon early landscape painting, the composition of Chongseokjeong Pavilion is remarkably unconventional. Stone pillars lined up in layers with the tallest in the center form a triangle. A sense of space is created by dividing the painting into three planes(foreground, middle-ground, and background) and placing the stone pillars in the foreground, Saseonbong Peaks in the middle-ground, and Saseonjeong Pavilion on the cliff in the background. The Saseonbong Peaks in the center occupy an overwhelming proportion of the picture plane. However, the vertical stone pillars fail to form an organic relation and are segmented and flat. The painter of Chongseokjeong Pavilion had not yet developed a three-dimensional or natural spatial perception. The white lower and dark upper portions of the stone pillars emphasize their loftiness. The textures and cracks of the dense stone pillars were rendered by first applying light ink to the surfaces and then adding fine lines in dark ink. Here, the tip of the brush is pressed at an oblique angle and pulled down vertically, which shows an early stage of the development of axe-cut texture strokes. The contrast of black and white and use of vertical texture strokes signal the forthcoming trend toward the Zhe School painting style. Each and every contour and crack on the stone pillars is unique, which indicates an effort to accentuate their actual characteristics. The birds sitting above the stone pillars, waves, and the foam of breaking waves are all vividly described, not simply in repeated brushstrokes. The configuration of natural features shown in the above-mentioned Gyeongpodae Pavilion and Chongseokjeong Pavilion changes in other later paintings of the two scenic spots. In the Gyeongpodae Pavilion, Jukdo Island is depicted in the foreground, Gyeongpoho Lake in the middle-ground, and Gyeongpodae Pavilion and Odaesan Mountain in the background. This composition differs from the typical configuration of other Gyeongpodae Pavilion paintings from the eighteenth century that place Gyeongpodae Pavilion in the foreground and the sea in the upper section. In Chongseokjeong Pavilion, stone pillars are illustrated using a perspective viewing them from the sea, while other paintings depict them while facing upward toward the sea. These changes resulted from the established patterns of compositions used in Jeong Seon(1676~1759) and Kim Hong-do(1745~ after 1806)'s paintings of Gwandong regions. However, the configuration of the sixteenth-century Gyeongpodae Pavilion, which seemed to have no longer been used, was employed again in late Joseon folk paintings such as Gyeongpodae Pavilion in Gangneung. Famous scenic spots in the Gwandong region were painted from early on. According to historical records, they were created by several painters, including Kim Saeng(711~?) from the Goryeo Dynasty and An Gyeon(act. 15th C.) from the early Joseon period, either on a single scroll or over several panels of a folding screen or several leaves of an album. Although many records mention the production of paintings depicting sites around the Gwandong region, there are no other extant examples from this era beyond the paintings of Gyeongpodae Pavilion and Chongseokjeong Pavilion discussed in this paper. These two paintings are thought to be the earliest works depicting the Gwandong regions thus far. Moreover, they hold art historical significance in that they present information on the tradition of producing folding screens on the Gwandong region. In particular, based on the contents of the colophon written for Chongseokjeong Pavilion, the original folding screen is presumed to have consisted of eight panels. This proves that the convention of painting eight views of Gwangdong had been established by the late sixteenth century. All of the existing works mentioned as examples of sixteenth-century real scenery landscape painting show only partial elements of real scenery landscape painting since they were created as depictions of notable social gatherings or as a documentary painting for practical and/or official purposes. However, a primary objective of the paintings of Gyeongpodae Pavilion and Chongseokjeong Pavilion was to portray the ever-changing and striking nature of this real scenery. Moreover, Park Chung-gan wrote a colophon and added a poem on his admiration of the scenery he witnessed during his trip and ruminated over the true character of nature. Thus, unlike other previously known real-scenery landscape paintings, these two are of great significance as examples of real-scenery landscape paintings produced for the simple appreciation of nature. Gyeongpodae Pavilion and Chongseokjeong Pavilion are noteworthy in that they are the earliest remaining examples of the historical tradition of reflecting a sightseeing trip in painting accompanied by poetry. Furthermore, and most importantly, they broaden the understanding of Korean real-scenery landscape painting by presenting varied forms, compositions, and perspectives from sixteenth-century real-scenery landscape paintings that had formerly been unfound.