• 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.

• Clinical and Experimental Pediatrics
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• v.50 no.1
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• pp.33-39
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• 2007

Purpose : In spite of medical advances, empyema is a serious complication of pneumonia in children. Vaccination practices and antibiotic prescribing practices promote the change of clinical manifestations of empyema and causative organisms. So we made a nationwide clinical observation of 122 cases of empyema in children from 32 hospitals during the 5 year period from September 1999 to August 2004. Methods : Demographic data, and clinical information on the course and management of empyema patients were collected retrospectively from medical records in secondary and tertiary hospitals in Korea. Results : One hundred twenty two patients were enrolled from 35 hospitals. The most frequent age group was 1-3 years, accounting for 48 percent of all cases. The male to female sex ratio was 1.2:1. The main symptoms were cough, fever, respiratory difficulty, lethargy and chest pain in order of frequency. Hematologic findings on admission revealed decreased hemoglobin levels ($10.4{\pm}1.6g/dL$) and increased leukocyte counts ($16,234.3{\pm}10,601.8/{\mu}L$). Pleural fluid obtained from patients showed high leukocyte counts ($30,365.8{\pm}64,073.0/{\mu}L$), high protein levels ($522.3{\pm}1582.3g/dL$), and low glucose levels ($88.1{\pm}523.5mg/dL$). Findings from pleural fluid cultures were positive in 80 cases(65.6 percent). The most common causative agent was Streptococcus pneumoniae. The majority of patients were treated with antibiotics and closed drainage. Some patients needed open drainage (16.4 percent) or decortication (3.3 percent). The mean duration of hospitalization was $28.6{\pm}15.3days$. Conclusion : We analyzed childhood empyema patients during a period of 5 years in Korean children. The most frequent age group was 1-3 years and the most common causative agent was Streptococcus pneumoniaeiae. The majority of patients were treated with antibiotics and close drainage.

• Journal of Society of Preventive Korean Medicine
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• v.5 no.2
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• pp.69-92
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• 2001

The purposes of this study were to offer foundation making more certain standards of musculoskeletal disorder diagnosis, We researched musculoskeletal symptoms degrees, frequencies, and cares and then examined relation between musculoskeletal symptoms and diagnosis of musculoskeletal conditions using moire topography among workers at an automobile manufacturing plant. Therefore we propose the possibility of moire topography as diagnosing utilities of musculoskeletal disorders. Methods: This study was to examine the general characteristics, complaints of musculoskeletal symptoms, and work-related musculoskeletal disorder rates of cervicobrachial and lumbar area by survey among 435 workers at an automobile manufacturing plant and then to show each frequency and percentage, In the diagnosis using moire topography, we studied pain control necessity of cervicobrachial and lumbar area, 435 subjects were classified by 5 levels: A(no symptoms), B(need management), C(need treatment) and then more divided by B1(light symptoms)/B2(heavy symptoms), C1(light symptoms)/C2(heavy symptoms), And musculoskeletal areas were divided by 2 parts, cervicobrachial area(neck, shoulder, arm&elbow, and wrist&hand) and lumbar area, Then, frequency and percentage of each musculoskeletal areas(cervicobrachial and lumbar area) were appeared. At last, Pearson's chi-square test analysis was utilized to observe the relation between diagnosis using moire topography and general characteristics and the relation between diagnosis using moire topography and work-related complaint of musculoskeletal symptoms of cervicobrachial and lumbar area, Results: The subjects employed for this research were categorized into; by gender, all of them were males(l00%): by age, under 35 years 12 %, 36-40 years 56.3%, 41-45 years 26.3 %, and above 46 years 5.3% with 36-40 years accounting for most of it. By living location, owned houses represented 69.7%, rented houses 23.4%, monthly-rented 1.6%, the others 5.3%; by education, middle school and lower represented 3.0%, high school 89.4%, and junior college and higher 7.6% with high school occupying most of the group. By marital status, married represented 95.2%, unmarried 4.1%, and the others 0.7% with most of them married; by alcohol, drinking represented 81.8% and non-drinking 18.2%; by smoking status, smoking represented 53.6%, non-smoking 46.4% with no big difference between them. By working time(hours/week), below 50 represented 26.9%, 50-60 67.6%, above 60 5.5%; by working time(hours/day), below 9 represented 21.6%, 10-12 73.1%, above 13 5.3%; by job tenure(years), below 10 represented 25.1%, 11-15 54.3%, 16-20 15.2%, above 21 5.5%. By personal income per year, below 30 million won represented 11.0%, 30-40 84.8%, above 40 4.1%; by sleeping hours, below 6 hours represented 26.7%, 7-8 hours 69.9%, above 9 hours 3.4%. Complaint rates of musculoskeletal symptoms and work-related musculoskeletal disorder rates were 63.9% and 54.9% with shoulder area occupying most of both them. By pain degree of musculoskeletal symptoms, shoulder area represented $2.73{\pm}0.84$, lumbar area $2.66{\pm}0.86$, wrist and hand area $2.59{\pm}0.86$, neck area $2.55{\pm}0.74$, and arm and elbow area $2.48{\pm}0.71$. By cares about musculoskeletal symptoms, taking medication or care represented 34.4%-46.7%, absence or leave 15.4%-28.7%, and job transfer 6.3%-11.5%. So experienced cases more than one thing among cares about musculoskeletal symptoms represented 39.6%-54%. In the diagnosis using moire topography, pain control necessity of cervicobrachial area was shown below; A(no symptoms) 20.7%, B1(need management/light symptoms) 64.6%, B2(need management/heavy symptoms) 11.5%, C1(need treatment/light symptoms) 3.0%, C2(need treatment/heavy symptoms) 0.2%. By lumbar area, A(no symptoms) 8.7%, B1(need management/light symptoms) 52.2%, B2(need management/heavy symptoms) 30.3%, C1(need treatment/light symptoms) 8.7%, C2(need treatment/heavy symptoms) was none. In the relation between pain control necessity and general characteristics, age(P=0.013), education(P=0.000), and job tenure(P=0.012) with pain control necessity showed differences with significance. The relation between pain control necessity and complaint of musculoskeletal symptoms of cervicobrachial and lumbar area showed no difference with significance; in cervicobrachial area represented P=0.708, lumbar area P=0.318 Conclusions: This study for musculoskeletal symptoms on workers at automobile manufacturing plant showed that complaint rates of musculoskeletal symptoms for cervicobrachial and lumbar area were so high, 63.9%. But Pearson's chi-square test analysis was utilized to study the relation between musculoskeletal symptoms and the diagnosis using moire topography, showed no differences with significance. They have no differences with significance, but the prevalence rates of diagnosis using moire topography for cervicobrachial and lumbar area were more higher than complaint rates of musculoskeletal symptoms; complaint rates of musculoskeletal symptoms were 52.4%, 34.5% and the diagnosis using moire topography were 79.3%, 91.3% for cervicobrachial and lumbar area. The results of this study indicate that the diagnosis using moire topography can find weak musculoskeletal disorders that an individual can not feel, not be judged work-related musculoskeletal disease. Therefore, this study has an important meaning that diagnosis using moire topography can predict and control own physical condition complete musculoskeletal disorders beforehand, since oriental medicine theory considers that prevention is important.