• 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.

• Asian-Australasian Journal of Animal Sciences
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• v.15 no.1
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• pp.124-136
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• 2002

As an official journal of the Asian-Australasian Association of Animal Production Societies (AAAP), the Asian-Australasian Journal of Animal Sciences (AJAS) was born in February 1987 and the first issue (Volume 1, Number 1) was published in March 1988 under the Editorship of Professor In K. Han (Korea). By the end of 2001, a total of 84 issues in 14 volumes and 1,761 papers in 11,462 pages had been published. In addition to these 14 volumes, a special issue entitled "Recent Advances in Animal Nutrition" (April, 2000) and 3 supplements entitled "Proceedings of the 9th AAAP Animal Science Congress" (July, 2000) were also published. Publication frequency has steadily increased from 4 issues in 1988, to 6 issues in 1997 and to 12 issues in 2000. The total number of pages per volume and the number of original or review papers published also increased. Some significant milestones in the history of the AJAS include that (1) it became a Science Citation Index (SCI) journal in 1997, (2) the impact factor of the journal improved from 0.257 in 1999 to 0.446 in 2000, (3) it became a monthly journal (12 issues per volume) in 2000, (4) it adopted an English editing system in 1999, and (5) it has been covered in "Current Contents/Agriculture, Biology and Environmental Science since 2000. The AJAS is subscribed by 842 individuals or institutions. Annual subscription fees of US$ 50 (Category B) or US$ 70 (Category A) for individuals and US$ 70 (Category B) or US$ 120 (Category A) for institutions are much less than the actual production costs of US$ 130. A list of the 1,761 papers published in AJAS, listed according to subject area, may be found in the AJAS homepage (http://www.ajas.snu.ac.kr) and a very well prepared "Editorial Policy with Guide for Authors" is available in the Appendix of this paper. With regard to the submission status of manuscripts from AAAP member countries, India (235), Korea (235) and Japan (198) have submitted the most manuscripts. On the other hand, Mongolia, Nepal, and Papua New Guinea have never submitted any articles. The average time required from submission of a manuscript to printing in the AJAS has been reduced from 11 months in 1997-2000 to 7.8 months in 2001. The average rejection rate of manuscripts was 35.3%, a percentage slightly higher than most leading animal science journals. The total number of scientific papers published in the AJAS by AAAP member countries during a 14-year period (1988-2001) was 1,333 papers (75.7%) and that by non- AAAP member countries was 428 papers (24.3%). Japanese animal scientists have published the largest number of papers (397), followed by Korea (275), India (160), Bangladesh (111), Pakistan (85), Australia (71), Malaysia (59), China (53), Thailand (53), and Indonesia (34). It is regrettable that the Philippines (15), Vietnam (10), New Zealand (8), Nepal (2), Mongolia (0) and Papua New Guinea (0) have not actively participated in publishing papers in the AJAS. It is also interesting to note that the top 5 countries (Bangladesh, India, Japan, Korea and Pakistan) have published 1,028 papers in total indicating 77% of the total papers being published by AAAP animal scientists from Vol. 1 to 14 of the AJAS. The largest number of papers were published in the ruminant nutrition section (591 papers-44.3%), followed by the non-ruminant nutrition section (251 papers-18.8%), the animal reproduction section (153 papers-11.5%) and the animal breeding section (115 papers-8.6%). The largest portion of AJAS manuscripts was reviewed by Korean editors (44.3%), followed by Japanese editors (18.1%), Australian editors (6.0%) and Chinese editors (5.6%). Editors from the rest of the AAAP member countries have reviewed slightly less than 5% of the total AJAS manuscripts. It was regrettably noticed that editorial members representing Nepal (66.7%), Mongolia (50.0%), India (35.7%), Pakistan (25.0%), Papua New Guinea (25.0%), Malaysia (22.8%) and New Zealand (21.5%) have failed to return many of the manuscripts requested to be reviewed by the Editor-in-Chief. Financial records show that Korea has contributed the largest portion of production costs (68.5%), followed by Japan (17.3%), China (8.3%), and Australia (3.5%). It was found that 6 AAAP member countries have contributed less than 1% of the total production costs (Bangladesh, India, Indonesia, Malaysia, Papua New Guinea and Thailand), and another 6 AAAP member countries (Mongolia, Nepal and Pakistan, Philippine and Vietnam) have never provided any financial contribution in the form of subscriptions, page charges or reprints. It should be pointed out that most AAAP member countries have published more papers than their financial input with the exception of Korea and China. For example, Japan has published 29.8% of the total papers published in AJAS by AAAP member countries. However, Japan has contributed only 17.3% of total income. Similar trends could also be found in the case of Australia, Bangladesh, India, Indonesia, Malaysia and Thailand. A total of 12 Asian young animal scientists (under 40 years of age) have been awarded the AJAS-Purina Outstanding Research Award which was initiated in 1990 with a donation of US$ 2,000-3,000 by Mr. K. Y. Kim, President of Agribrands Purina Korea Inc. In order to improve the impact factor (citation frequency) and the financial structure of the AJAS, (1) submission of more manuscripts of good quality should be encouraged, (2) subscription rate of all AAAP member countries, especially Category B member countries should be dramatically increased, (3) a page charge policy and reprint ordering system should be applied to all AAAP member countries, and (4) all AAAP countries, especially Category A member countries should share more of the financial burden (advertisement revenue or support from public or private sector).

• The Korean Journal of Air & Space Law and Policy
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• v.24 no.1
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• pp.35-58
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• 2009

A treaty that governs the compensation on damage caused by aircraft to the third parties on surface was first adopted in Rome in 1933, but without support from the international aviation community it was replaced by another convention adopted again in Rome in 1952. Despite the increase of the compensation amount and some improvements to the old version, the Rome Convention 1952 with 49 State parties as of today is not considered universally accepted. Neither is the Montreal Protocol 1978 amending the Rome Convention 1952, with only 12 State parties excluding major aviation powers like USA, Japan, UK, and Germany. Consequently, it is mostly the local laws that apply to the compensation case of surface damage caused by the aircraft, contrary to the intention of those countries and people who involved themselves in the drafting of the early conventions on surface damage. The terrorist attacks 9/11 proved that even the strongest power in the world like the USA cannot with ease bear all the damages done to the third parties by the terrorist acts involving aircraft. Accordingly as a matter of urgency, the International Civil Aviation Organization(ICAO) picked up the matter and have it considered among member States for a few years through its Legal Committee before proposing for adoption as a new treaty in the Diplomatic Conference held in Montreal, Canada 20 April to 2 May 2009. Accordingly, two treaties based on the drafts of the Legal Committee were adopted in Montreal by consensus, one on the compensation for general risk damage caused by aircraft, the other one on compensation for damage from acts of unlawful interference involving aircraft. Both Conventions improved the old Convention/Protocol in many aspects. Deleting 'surface' in defining the damage to the third parties in the title and contents of the Conventions is the first improvement because the third party damage is not necessarily limited to surface on the soil and sea of the Earth. Thus Mid-air collision is now the new scope of application. Increasing compensation limit in big gallop is another improvement, so is the inclusion of the mental injury accompanied by bodily injury as the damage to be compensated. In fact, jurisprudence in recent years for cases of passengers in aircraft accident holds aircraft operators to be liable to such mental injuries. However, "Terror Convention" involving unlawful interference of aircraft has some unique provisions of innovation and others. While establishing the International Civil Aviation Compensation Fund to supplement, when necessary, the damages that exceed the limit to be covered by aircraft operators through insurance taking is an innovation, leaving the fate of the Convention to a State Party, implying in fact the USA, is harming its universality. Furthermore, taking into account the fact that the damage incurred by the terrorist acts, where ever it takes place targeting whichever sector or industry, are the domain of the State responsibility, imposing the burden of compensation resulting from terrorist acts in the air industry on the aircraft operators and passengers/shippers is a source of serious concern for the prospect of the Convention. This is more so when the risks of terrorist acts normally aimed at a few countries because of current international political situation are spread out to many innocent countries without quid pro quo.

• Asia pacific journal of information systems
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• v.24 no.4
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• pp.443-472
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• 2014

To survive in the global competitive environment, enterprise should be able to solve various problems and find the optimal solution effectively. The big-data is being perceived as a tool for solving enterprise problems effectively and improve competitiveness with its' various problem solving and advanced predictive capabilities. Due to its remarkable performance, the implementation of big data systems has been increased through many enterprises around the world. Currently the big-data is called the 'crude oil' of the 21st century and is expected to provide competitive superiority. The reason why the big data is in the limelight is because while the conventional IT technology has been falling behind much in its possibility level, the big data has gone beyond the technological possibility and has the advantage of being utilized to create new values such as business optimization and new business creation through analysis of big data. Since the big data has been introduced too hastily without considering the strategic value deduction and achievement obtained through the big data, however, there are difficulties in the strategic value deduction and data utilization that can be gained through big data. According to the survey result of 1,800 IT professionals from 18 countries world wide, the percentage of the corporation where the big data is being utilized well was only 28%, and many of them responded that they are having difficulties in strategic value deduction and operation through big data. The strategic value should be deducted and environment phases like corporate internal and external related regulations and systems should be considered in order to introduce big data, but these factors were not well being reflected. The cause of the failure turned out to be that the big data was introduced by way of the IT trend and surrounding environment, but it was introduced hastily in the situation where the introduction condition was not well arranged. The strategic value which can be obtained through big data should be clearly comprehended and systematic environment analysis is very important about applicability in order to introduce successful big data, but since the corporations are considering only partial achievements and technological phases that can be obtained through big data, the successful introduction is not being made. Previous study shows that most of big data researches are focused on big data concept, cases, and practical suggestions without empirical study. The purpose of this study is provide the theoretically and practically useful implementation framework and strategies of big data systems with conducting comprehensive literature review, finding influencing factors for successful big data systems implementation, and analysing empirical models. To do this, the elements which can affect the introduction intention of big data were deducted by reviewing the information system's successful factors, strategic value perception factors, considering factors for the information system introduction environment and big data related literature in order to comprehend the effect factors when the corporations introduce big data and structured questionnaire was developed. After that, the questionnaire and the statistical analysis were performed with the people in charge of the big data inside the corporations as objects. According to the statistical analysis, it was shown that the strategic value perception factor and the inside-industry environmental factors affected positively the introduction intention of big data. The theoretical, practical and political implications deducted from the study result is as follows. The frist theoretical implication is that this study has proposed theoretically effect factors which affect the introduction intention of big data by reviewing the strategic value perception and environmental factors and big data related precedent studies and proposed the variables and measurement items which were analyzed empirically and verified. This study has meaning in that it has measured the influence of each variable on the introduction intention by verifying the relationship between the independent variables and the dependent variables through structural equation model. Second, this study has defined the independent variable(strategic value perception, environment), dependent variable(introduction intention) and regulatory variable(type of business and corporate size) about big data introduction intention and has arranged theoretical base in studying big data related field empirically afterwards by developing measurement items which has obtained credibility and validity. Third, by verifying the strategic value perception factors and the significance about environmental factors proposed in the conventional precedent studies, this study will be able to give aid to the afterwards empirical study about effect factors on big data introduction. The operational implications are as follows. First, this study has arranged the empirical study base about big data field by investigating the cause and effect relationship about the influence of the strategic value perception factor and environmental factor on the introduction intention and proposing the measurement items which has obtained the justice, credibility and validity etc. Second, this study has proposed the study result that the strategic value perception factor affects positively the big data introduction intention and it has meaning in that the importance of the strategic value perception has been presented. Third, the study has proposed that the corporation which introduces big data should consider the big data introduction through precise analysis about industry's internal environment. Fourth, this study has proposed the point that the size and type of business of the corresponding corporation should be considered in introducing the big data by presenting the difference of the effect factors of big data introduction depending on the size and type of business of the corporation. The political implications are as follows. First, variety of utilization of big data is needed. The strategic value that big data has can be accessed in various ways in the product, service field, productivity field, decision making field etc and can be utilized in all the business fields based on that, but the parts that main domestic corporations are considering are limited to some parts of the products and service fields. Accordingly, in introducing big data, reviewing the phase about utilization in detail and design the big data system in a form which can maximize the utilization rate will be necessary. Second, the study is proposing the burden of the cost of the system introduction, difficulty in utilization in the system and lack of credibility in the supply corporations etc in the big data introduction phase by corporations. Since the world IT corporations are predominating the big data market, the big data introduction of domestic corporations can not but to be dependent on the foreign corporations. When considering that fact, that our country does not have global IT corporations even though it is world powerful IT country, the big data can be thought to be the chance to rear world level corporations. Accordingly, the government shall need to rear star corporations through active political support. Third, the corporations' internal and external professional manpower for the big data introduction and operation lacks. Big data is a system where how valuable data can be deducted utilizing data is more important than the system construction itself. For this, talent who are equipped with academic knowledge and experience in various fields like IT, statistics, strategy and management etc and manpower training should be implemented through systematic education for these talents. This study has arranged theoretical base for empirical studies about big data related fields by comprehending the main variables which affect the big data introduction intention and verifying them and is expected to be able to propose useful guidelines for the corporations and policy developers who are considering big data implementationby analyzing empirically that theoretical base.

• The Korean Journal of Air & Space Law and Policy
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• v.18
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• pp.135-183
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• 2003

Aerospace force is a determining factor in a modem war. The combat field is expanding to space. Thus, the legitimacy of establishing aerospace force is no longer an debating issue, but "how should we establish aerospace force" has become an issue to the military. The standard limiting on the military use of space should be non-aggressive use as asserted by the U.S., rather than non-military use as asserted by the former Soviet Union. The former Soviet Union's argument is not even strongly supported by the current Russia government, and realistically is hard to be applied. Thus, the multi-purpose satellite used for military surveillance or a commercial satellite employed for military communication are allowed under the U.S. principle of peaceful use of space. In this regard, Air Force may be free to develop a military surveillance satellite and a communication satellite with civilian research institute. Although MTCR, entered into with the U.S., restricts the development of space-launching vehicle for the export purpose, the development of space-launching vehicle by the Korea Air Force or Korea Aerospace Research Institute is beyond the scope of application of MTCR, and Air Force may just operate a satellite in the orbit for the military purpose. The primary task for multi-purpose satellite is a remote sensing; SAR sensor with high resolution is mainly employed for military use. Therefore, a system that enables Air Force, the Korea Aerospace Research Institute, and Agency for Defense Development to conduct joint-research and development should be instituted. U.S. Air Force has dismantled its own space-launching vehicle step by step, and, instead, has increased using private space launching vehicle. In addition, Military communication has been operated separately from civil communication services or broadcasting services due to the special circumstances unique to the military setting. However, joint-operation of communication facility by the military and civil users is preferred because this reduces financial burden resulting from separate operation of military satellite. During the Gulf War, U.S. armed forces employed commercial satellites for its military communication. Korea's participation in space technology research is a little bit behind in time, considering its economic scale. In terms of budget, Korea is to spend 5 trillion won for 15 years for the space activities. However, Japan has 2 trillion won annul budget for the same activities. Because the development of space industry during initial fostering period does not apply to profit-making business, government supports are inevitable. All space development programs of other foreign countries are entirely supported by each government, and, only recently, private industry started participating in limited area such as a communication satellite and broadcasting satellite, Particularly, Korea's space industry is in an infant stage, which largely demands government supports. Government support should be in the form of investment or financial contribution, rather than in the form of loan or borrowing. Compared to other advanced countries in space industry, Korea needs more budget and professional research staff. Naturally, for the efficient and systemic space development and for the prevention of overlapping and distraction of power, it is necessary to enact space-related statutes, which would provide dear vision for the Korea space development. Furthermore, the fact that a variety of departments are running their own space development program requires a centralized and single space-industry development system. Prior to discussing how to coordinate or integrate space programs between Agency for Defense Development and the Korea Aerospace Research Institute, it is a prerequisite to establish, namely, "Space Operations Center"in the Air Force, which would determine policy and strategy in operating space forces. For the establishment of "Space Operations Center," policy determinations by the Ministry of National Defense and the Joint Chief of Staff are required. Especially, space surveillance system through using a military surveillance satellite and communication satellite, which would lay foundation for independent defense, shall be established with reference to Japan's space force plan. In order to resolve issues related to MTCR, Air Force would use space-launching vehicle of the Korea Aerospace Research Institute. Moreover, defense budge should be appropriated for using multi-purpose satellite and communication satellite. The Ministry of National Defense needs to appropriate 2.5 trillion won budget for space operations, which amounts to Japan's surveillance satellite operating budges.