• Title/Summary/Keyword: 이전가격

Search Result 236, Processing Time 0.027 seconds

A Study on Transfer Pricing Taxation Regulations - Laying Focus on Intangibles (우리 나라의 이전가격과세제도(移轉價格課稅制度)에 관한 연구 - 무형재화(無形財貨)를 중심(中心)으로 -)

  • Kim, Ju-Teak
    • Korean Business Review
    • /
    • v.11
    • /
    • pp.319-341
    • /
    • 1998
  • Transfer pricing is a process for determining the prices of products, technology and services among affiliated companies. Although taxation problems arising from international investment are not now, they have become more important in recent years as a consequence of the growing internationalization of economic activities. So, trans pricing to shift their income and expenses from one country to another has made it difficult for tax administrations to impose tax collectly. Our government also applies arm' length methods to decide equitable tax. In the case of intangibles, because of the characteristics of the market, it is not easy to find the comparable uncontrolled transactions and it is almost impossible to apply cost=plus method or resale price method. This paper treats these problem, examining U.S. regulations and OECD guidelines and analysing the practice of transactions and the application of other methods.

  • PDF

유상증자의 주가변화 -가격압박가설, 부의 이전가설, 정보전달가설

  • Lee, Yong-Hwan
    • The Korean Journal of Financial Management
    • /
    • v.11 no.2
    • /
    • pp.161-173
    • /
    • 1994
  • 유상증자의 주가하락에 대하여 유상증자 공시일전 내부자순매수를 종속변수로 설정하여 선형회귀분석한 결과, 이전의 논문결과와는 달리 유상증자규모효와 자본구조변화효과는 보이지 않았으며, 반면에 유상증자의 주가하락이 내부자순매수와 통계적 유의성이 높은 비례관계가 있음을 밝혀 내었다. 이 결과는 유상증자규모효과로 인한 가격 압박가설과 자본구조변화효과로 인한 부의 이전가설을 기각시키고 정보전달가설이 유상증자의 주식 가격 하락현상을 설명하는 설득력 있는 가설임을 시사하고 있다.

  • PDF

Asymmetric Adjustment in Domestic Petroleum Prices Before and After the Opinet (국내석유제품가격의 국제유가 대칭성 분석 -Opinet(오피넷) 개통을 중심으로)

  • Koh, Yukyung
    • Environmental and Resource Economics Review
    • /
    • v.22 no.4
    • /
    • pp.581-612
    • /
    • 2013
  • Opinet is the system that has announced the daily domestic petroleum price data from April 2008. This study's goal is to examine if the domestic petroleum(gasoline and diesel) prices adjust their prices asymmetrically comparing before-Opinet with after-Opinet. The results of this study found the evidence of asymmetric domestic petroleum prices before the Opinet and the evidence of symmetric domestic petroleum prices after the Opinet. Also the domestic petroleum prices after the Opinet adjust upward/downward nearly twice as fast when its actual value is below/above its equilibrium. According to this study, the domestic petroleum market works more efficiently than before.

Thin Capitalization - The Arm's Length Approach through Blockchain

  • Lee, Jeong-Mi
    • Journal of the Korea Society of Computer and Information
    • /
    • v.25 no.10
    • /
    • pp.185-191
    • /
    • 2020
  • This article proposes the unified an arm's length price of transfer pricing for thin capitalization since the scope of permanent establishment has been enlarged under Digital Economy and the implementation of Blackchain system to resolve the drawback of finding an arm's length price. The rule of current thin capitalization runs against the non-discrimination of taxation of the tax treaties and the national treatment which deals fairly with goods, sercice and capital money within the country under the treaty of commerce and navigator. In addition, the information of comparable uncontrolled debt are not available of current system to prove the debt which is not subject to the rule of thin capitalization. The united an arm's length price of transfer pricing for thin capitalization can apply to foreign investment as well as domestic corporations, thereby resolving the problem of the non-discrimination of taxation of the tax treaties and the treaty of commerce and navigation. The availability of transaction level data through Blockchain platform to decide whether the debt can be subject to thin capitalization can resolve the issue of comparable uncontrolled debt transaction which can't be found in current business transactions. This article should shed light on the proposing of the unified an arm's length price of transfer pricing for thin capitalization and Blockchain system to prevent the income shifting. This propose provide implication for policymakers on current system of thin capitalization and arm's length principles.

Variation of Determinant Factor for Seoul Metropolitan Area's Housing and Rent Price in Korea (수도권 주택가격 결정요인 변화 연구)

  • Lee, Kyung-Ae;Park, Sang-Hak;Kim, Yong-Soon
    • Land and Housing Review
    • /
    • v.4 no.1
    • /
    • pp.43-54
    • /
    • 2013
  • This This paper investigates the variation of the factors to determinate housing price in Seoul metropolitan area after sub-prime financial crisis, in Korea, using a VAR model. The model includes housing price and housing rent (Jeonse) in Seoul metropolitan area from 1999 to 2011, and uses interest rate, real GDP, KOSPI, Producer Price Index and practices to impulse response and variance decomposition analysis to grasp the dynamic relation between a variable of macro economy and and a variable of housing price. Data is classified to 2 groups before and after the 3rd quater of 2008, when sub-prime crisis occurred; one is from the 1st quater of 1999 to the 3rd quater of 2008, and the other is from the 2nd quater of 1999 and the 4th quater of 2011. As a result, comparing before and after sub-prime crisis, housing price is more influenced by its own variation or Jeonse price's variation instead of interest rate and KOSPI. Both before and after sub-prime financial crisis, Jeonse price is also influenced by its own variation and housing price. While after sub-prime financial crisis, influences of Producer Price Index, KOSPI and interest rate were weakened, influence of real GDP is expanded. As housing price and housing rent are more influenced by real economy factors such as GDP, its own variation than before sub-prime financial crisis, the recent trend that the house prices is declined is difficult to be converted, considering domestic economic recession and uncertainty, continued by Europe financial crisis. In the future to activate the housing business, it ia necessary to promote purchasing power rather than relaxation of financial and supply regulation.

Changes in Factors Affecting International Grain Prices (국제곡물가격에 영향을 미치는 요인의 변화)

  • Choi, Sunkyu;Jung, Heonyong
    • The Journal of the Convergence on Culture Technology
    • /
    • v.5 no.2
    • /
    • pp.183-188
    • /
    • 2019
  • This study analyzed the effects of short-term interest rates, exchange rates and international oil prices on international grain prices using the EGARCH-GED model. The yield before one month of the international grain prices itself was found to have a significant effect on international grain prices for most periods. During the entire analysis period, none of the economic variables appeared to have a significant effect on international grain prices, whereas during the exchange fall period, only oil prices were shown to have a significant effect on international grain prices. In addition, during the pre-crisis period, interest rates, exchange rates and oil prices did not all have a significant effect, but during the post-crisis period only oil prices had a significant effect on international grain prices. It turns out that the factors affecting international grain prices are changing with the passage of time.

Analysis of the Relationship between House Price, Income Inequality and Macroeconomic Variables (주택가격, 소득불평등 및 거시경제변수간의 관계분석)

  • Kwon, Sun-Hee;Hyun, Seong-Min
    • Journal of Digital Convergence
    • /
    • v.17 no.1
    • /
    • pp.55-62
    • /
    • 2019
  • This study analyzed the relationship between housing price, purchase price, Gini coefficient, interest rate, and the employment, considering that the change in housing price was an important factor influencing macroeconomic variables and income inequality. The panel VAR model was constructed considering the panel data, and the Granger causality, Impulse response and Variance dispersion analysis were performed. As a result, when compared to before and after the global financial crisis, it was shown that the rent price had an effect on income inequality, but in the following period, both the rent price and the selling price affected the income inequality. And that it has a large impact on inequality. In addition, the causality between income inequality and employment rate, interest rate, and tax rate was confirmed. Therefore, it is expected that it will be a desirable policy to mitigate income inequality considering the influence of policy variables for economic activation including government real estate policy.

The Profit Sharing and Efficiency of a Joint Venture (공동사업의 이익분배와 효율성)

  • Wee, Jung-Bum;Jun, Sang-Gyung
    • The Korean Journal of Financial Management
    • /
    • v.25 no.1
    • /
    • pp.177-196
    • /
    • 2008
  • The megatrend of convergence in finance, telecommunication, and service industries is being spread over the whole industry. It has generated various kinds of contractual alliance or joint venture. Our paper builds a theoretical model for the profit sharing between two firms that participate in a joint venture. The model shows how the profit sharing rule affects the incentives of the participants, and, eventually, the efficiency. We derive the first-best solution of the profit sharing, where no incentive distortion exists. Then, we compare the incentive-affecting cases with the first best outcome, and assess the efficiency and the fairness of distribution. Our analysis shows that if we properly design the decision-making structure on transfer price and production quantity, we can reach the socially optimal efficiency.

  • PDF

Information Flow Effect Between the Stock Market and Bond Market (주식시장과 채권시장간의 정보 이전효과)

  • Choi, Cha-Soon
    • Journal of Convergence for Information Technology
    • /
    • v.10 no.3
    • /
    • pp.67-75
    • /
    • 2020
  • This paper investigated the information spillover effect between stock market and bond market with the KOSPI daily index and MMF yield data. The overall analysis period is from May 2, 1997 to August 30, 2019. The empirical analysis was conducted by dividing the period from May 2, 1997 to December 30, 2008 before the global financial crisis, and from December 30, 2008 to August 30, 2019 after the global financial crisis, and the overall analysis period. The analysis shows that the EGARCH model considering asymmetric variability is suitable. The price spillover effect and volatility spillover effect existed in both directions between the stock market and the bond market, and the price transfer effect was greater in the period before the global financial crisis than in the period after the global financial crisis. Asymmetric volatility in information between stock and bond markets appears to exist in both markets.