• 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.

• KDI Journal of Economic Policy
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• v.33 no.2
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• pp.111-143
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• 2011

As the 'jobless growth' is developing into a worldwide phenomenon, many countries try to recover a virtuous relationship between the growth and employment using various wage subsidy programs. This study focuses on wage subsidy to employers, labor demand-side wage subsidy for which one can think of two types-a tax credit(a flat wage subsidy) and a social insurance premium exemption(a proportional wage subsidy). For job creation, Korean government reintroduced a tax credit to small and medium-sized enterprises(SMEs) which have increased their employment level in 2010. But many experts has continuously insisted that it should be replaced with a social insurance premium exemption arguing only a few SMEs benefit from the tax credit as most of them are actually not paying any corporate or general income tax bills. However, as the insurance premium exemption accompanies an increase in the amount of budget with the coverage widen, one cannot confirm its cost effectiveness over the tax credit. This paper aims to provide a theoretical analysis to derive some formal conditions under which a social insurance premium exemption creates more jobs than a tax credit does given a budget constraint. We show that the former's dominance over the latter depends on whether there exists a dead zone of social insurance or not. If there does not exist a dead zone, a social insurance premium exemption is more desirable in many cases, whereas one cannot guarantees its dominance over a tax credit if there exists a dead zone. Therefore in order to realize its dominance, the government should minimize a dead zone so that most SMEs effectively benefit from the insurance premium exemption. In addition, applying discriminative exemption rates which reflect each firm's job conditions such as wage level and labor demand/supply sensitivity, the government try to enhance job creation effect.

• Journal of Platform Technology
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• v.9 no.4
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• pp.10-31
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• 2021

The digital tax, recently referred to as the Google tax was finally agreed at the 31st General Assembly of the OECD (October 8, 2021) with full support by 136 countries and will take effect from 2023. The purpose of this study is to analyze the digital tax prepared by the OECD for global MNEs, and to suggest the impacts on the Korean industry and to present the Korean governmental countermeasures. As the first study, we analyzed the international agreement on digital tax. In results, we found that even if global MNEs do not set up a business operation in overseas countries, if sales and profits are generated, 25% of the excess profit is borne as tax (pillar 1), and when MNEs do business in all the countries, they are liable to at least a 15% tax (pillar 2). We think that countries around the world have prepared a minimum countermeasure to protect their companies in anticipation that global MNEs will easily encroach on their markets in the future. As the second study, in order to discover the reason why the MNEs are so strong, we investigated the trends of Google and B2B SaaS companies in details. In results, we discovered that the global MNEs establishes a digital platform partnership ecosystem that enables them to enter foreign markets easily and expand rapidly. In conclusion, as a countermeasure for the Republic of Korea, governmental policies were proposed at the corporate (startup nurturing), industry, and national level respectively.

• Journal of Digital Convergence
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• v.22 no.3
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• pp.1-7
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• 2024

This study provides an in-depth analysis of the impact of the deepening reform and opening-up policies announced at the 20th CPC Central Committee's Plenary Session, particularly focusing on the <Foreign Investment Law> and its effects on the tax decisions and organizational restructuring of Korean companies operating in China. Using a comprehensive literature review and policy analysis, the study compares the dual legal structure and tax differences before and after the implementation of the law, assessing how legal unification has influenced the organizational forms and tax strategies of Korean companies. The findings indicate that the <Foreign Investment Law> has played a crucial role in enhancing legal consistency and tax equity between foreign-invested enterprises and domestic enterprises, thereby enabling Korean companies to manage their operations in the Chinese market more stably and efficiently. Additionally, in the context of the ongoing U.S.-China trade conflict, the law's provision of national treatment and tax benefits has proven to be a significant factor in the survival strategy of Korean companies in China. Future research should focus on empirically examining the long-term effects of this law and its impact on actual corporate performance.

• Journal of the Korea Society of Computer and Information
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• v.17 no.4
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• pp.147-153
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• 2012

This paper has investigated the impact of corporate donation expenditure which has recently drawn great attention in Korean society on businessl performance and conducted an empirical analysis on the causal relations. In addition, concurrent effect has been analyzed using cross-sectional data between two variables (corporate donation expenditure and business performance) while sequential effect has been examined using panel data. The result of this study can be summarized as follows: First, corporate donation expenditure had a positive impact on ROA and ROS. However, PER and ROE had no impact on corporate donation expenditure Second, cumulative effcet of corporate cash donation would have a bigger impact on short-term business performance than long-term performance. In the future, The results of this study is expect through cash donations in the social contribution to be more aggressive in carrying out social responsibilities.

• The Korean Journal of Franchise Management
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• v.7 no.2
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• pp.27-35
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• 2016

Purpose - The primary objective of this study is to investigate the impact of employee characteristics on employees' preference towards corporate pension products. This study can provide a guidance for maximization of benefits for employees and their affiliated corporation. Employee characteristics include average length of labour, wage system of annual salary, age, types of interest rates and size of corporation. Existing research generally concentrate on vitalizations of corporate pension product raising an imperfection, improvements, tax benefit analysis and legal consideration. Thus, this study intensively analyses the effect of employee attributes on firms' decision for corporate pension products, such as DB(defined benefit) and DC(defined contribution) type. Research design, data, and methodology - The data were collected using self-administrated questionnaire survey on corporate pension products from CEOs or HR directors 250 foreign-invested companies', purchasing pension plans in practice with domestic financial trustees (insurance companies, banks and security companies). Hypotheses testing was conducted using Logistic Regression analysis with SPSS/PC+ 21.0. Results - The findings of the study are as follows. Employees with the long length of labour are more likely to have DB plan; more likely to prefer DC plan with the dividend distribution product regarding the types of interest rate. SMEs(less than 100 employees) are more likely to select DC plan whereas high fluctuation in wage with annual salary has no impacts. In addition, the ages has no significant effect on the preference. Conclusions - This study has examined with the empirical testing that employees' variable attributes and qualities are one of the vital factors for corporation pension plan selection. Currently, majority employees are highly likely to join DB plan and Defined interest types. Corporation with less than 10 employees prefer IRP scheme while most of corporation are intended to join DC plan. In a very near future, corporation more than 300 employees will be required to purchase mandatory plan under national regulation. For maximization of employees' contentment to corporation pension insurance and for complementing the flaws of existing plans, the future studies shall also research in a perspective of employee benefit.

• Journal of the Korean Geographical Society
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• v.43 no.6
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• pp.914-937
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• 2008

This paper suggests the 'growing together' strategy through the instrument of horizontal equalization development fund collected by Seoul Metropolitan Area(SMA) governments. This method is a kind of SMA's special grant composed of the real estate related taxes, corporate tax, property-related capital gain tax,. development gain, various charges by 'The Framework Act on the Management of Charges', the sharing of tax revenues. Also the up-zoning and exemption of capital gain tax burden in SMA's plant site sale process is suggested as a another method. Finally governance strategy with contract theories and social agreements point out how mutual duties between two parties can be efficiently managed. Governance system among levels of government is executive strategy that could be used as clarifying and learning tools for co-development by SMA's special grant.

• Journal of Practical Engineering Education
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• v.10 no.2
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• pp.149-157
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• 2018

China evaluates corporate management activities based on the policies and assessment criteria of corporate social responsibility (CSR) based on the national development plan goals. This assessment should be understood in advance as a key issue for Korean companies into the Chinese market. Therefore, this research was presented to analyze the process, trends and related systems of CSR based on Chinese political specialties. Through this is aimed at utilizing this study as a CSR implementation strategy and CSR training frame for companies considering to China in order to understand the reality of CSR in China and applying it to business strategy.

• Asia-Pacific Journal of Business
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• v.11 no.3
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• pp.95-106
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• 2020

Purpose - This study examines the information effect of the disclosure of new office investments on the Korean stock market and investigates determinant of performance of sample firms. Design/methodology/approach - The sample consists of companies listed on the Korean Exchange that announced investments in new office construction for eleven-years from January 2007 to December 2017. It analyzes excess return using event study methodology and studies the determinants of abnormal return with multiple regression analysis. Findings - We find that abnormal returns of the short and long window are positive on average and statistically significant. In particular, CAR of high growth subsample is a larger positive return than that of the low one both short and long window. Difference in abnormal returns by investment size is observed only in short time window. But there is not observed difference by cash holding level. Research implications or Originality - This finding is able to be added to the evidence of the theory of corporate value maximization academically. Moreover, it shows the possibility that building a new office can have a positive effect on corporate value. It is expected to help investors make decisions because it can provide useful information to market participants in practice.

• Asia-Pacific Journal of Business
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• v.14 no.3
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• pp.205-219
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• 2023

Purpose - This study examines the effect of corporate debt characteristics on the relationship between anti-takeover provision and the cost of debt. Design/methodology/approach - The study analyzes a sample of non-financial firms listed on the stock market with December fiscal year-end from 2011 to 2018. Debt default risk (debt size, liquidity ratio, interest coverage ratio, loss occurrence) and the issuance of bonds are utilized as measures of corporate debt characteristics. Findings - First, it is observed that creditors of firms with anti-takeover provision demand higher returns as the debt default risk of these firms increases. Second, for firms issuing bonds, it is found that bondholders in companies with anti-takeover provision also seek higher returns. Research implications or Originality - This study contributes by demonstrating that the effect of anti-takeover provision on creditors can vary depending on corporate debt characteristics. Particularly, the study highlights the importance of a firm's debt default risk and creditor distinction (bondholders vs. regular creditors) as significant factors that may influence perceptions of anti-takeover provision.