This study was conducted to measure methane (
This research traced the characteristics of the semantic landscape, construction intent, landscape composition, and geomantic conditions of the area subject to the research based on the research methods of 'field investigation, document studies, and interviews,' centering around the entire area of Gokseong Hamheo-pavilion (Jeonnam Tangible Cultural Assets No. 160). The result of the research, specifically revealing the forms and methods by which the reciprocal view of nature and landscape composition appearing in the landscape of the entire area of Hamheo-pavilion, as part of the analysis and interpretation over the view-based construction characteristics and position of the entire area of Gokseong Hamheo-pavilion, can be summarized as follows. First, Hamheo-pavilion is a pavilion built as a resting area and as a venue for educational activities in 1543 in the nearby areas after Gwang-hyeon Sim founded Gunjichon-jeongsa for educational activities and dwelling purposes at Gunchon at the 30th year of King Jungjong. Gunchon, where Hamheo-pavilion and Gunjichon-jeongsa is located, exhibits the typical form having water in the front, facing Sunja-river(present Seomjin-river), and a mountain in the back side. Dongak-mountain, which is a guardian mountain, is in a snail-type form where cows leisurely ruminate and lie on the riverside, and the Hamheo-pavilion area is said to be an area bordering on one's way of enjoying peace and richness as it is a place with plentiful grass bushes available for cows to ruminate and lie down while sheppards may leisurely play their flutes at the riverside. The back hill of Hamheo-pavilion is a blood vessel that enters the water into the underwater palace of the turtle, and the building sitting on the turtle's back is Hamheo-pavilion, and the Guam-jodae(龜巖釣臺) and lava on the southern side below the cliff can be interpreted to be the underwater fairly land wanted by the turtle.6) Second, Hamheo-pavilion is the scenery viewpoint of Sungang-Cheongpung (3rd Scenery) and Seolsan-Nakjo(雪山落照, 9th Scenery) among the eight sceneries of Gokseong, while also the scenery viewpoint of Hamheo-Sunja(2nd Scenery) and Cheonma-Gwiam(天馬歸岩, 3rd Scenery) among the eight sceneries of Ipmyeon. On the other hand, the pavilion is reproduced through the aesthetics of bends through sensible penetration and transcendental landscape viewed based on the Confucian-topos and ethics as the four bends among the five bends of Sunja-river arranged in the 'Santaegeuk(山太極) and Sutaeguek(水太極, formation of the yin-yang symbol by the mountain and water)' form, which is alike the connection of yin and yang. In particular, when based on the description over Mujinjeong (3rd Bend), Hoyeonjeong(4th Bend), andHapgangjeong(2nd Bend) among the five bends of Sunja-river in the records of Bibyeonsainbangan-jido(duringthe 18th century) and Okgwahyeonji(1788), the scenery of the five bends of Sunja-river allow to glimpse into its reputation as an attraction-type connected scenery in the latter period of the Joseon era, instead of only being perceived of its place identity embracing the fairyland world by crossing in and out of the world of this world and nirvana. Third, Hamheo-pavilion, which exhibits exquisite aesthetics of vacancy, is where the 'forest landscape composed of old big trees such as oak trees, oriental oak trees, and pine trees,' 'rock landscape such as Guam-jodae, lava, and layered rocks' and 'cultural landscape of Gunchon village' is spread close by. In the middle, it has a mountain scenery composed of Sunja-river, Masan-peak, and Gori-peak, and it is a place where the scenery by Gori-peak, Masan-peak, Mudeung-mountain, and Seol-mountain is spread and open in
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.