• Journal of Intelligence and Information Systems
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• v.20 no.1
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• pp.149-161
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• 2014

The export of domestic public services to overseas markets contains many potential obstacles, stemming from different export procedures, the target services, and socio-economic environments. In order to alleviate these problems, the business incubation platform as an open business ecosystem can be a powerful instrument to support the decisions taken by participants and stakeholders. In this paper, we propose an ontology model and its implementation processes for the business incubation platform with an open and pervasive architecture to support public service exports. For the conceptual model of platform ontology, export case studies are used for requirements analysis. The conceptual model shows the basic structure, with vocabulary and its meaning, the relationship between ontologies, and key attributes. For the implementation and test of the ontology model, the logical structure is edited using Prot$\acute{e}$g$\acute{e}$ editor. The core engine of the business incubation platform is the simulator module, where the various contexts of export businesses should be captured, defined, and shared with other modules through ontologies. It is well-known that an ontology, with which concepts and their relationships are represented using a shared vocabulary, is an efficient and effective tool for organizing meta-information to develop structural frameworks in a particular domain. The proposed model consists of five ontologies derived from a requirements survey of major stakeholders and their operational scenarios: service, requirements, environment, enterprise, and county. The service ontology contains several components that can find and categorize public services through a case analysis of the public service export. Key attributes of the service ontology are composed of categories including objective, requirements, activity, and service. The objective category, which has sub-attributes including operational body (organization) and user, acts as a reference to search and classify public services. The requirements category relates to the functional needs at a particular phase of system (service) design or operation. Sub-attributes of requirements are user, application, platform, architecture, and social overhead. The activity category represents business processes during the operation and maintenance phase. The activity category also has sub-attributes including facility, software, and project unit. The service category, with sub-attributes such as target, time, and place, acts as a reference to sort and classify the public services. The requirements ontology is derived from the basic and common components of public services and target countries. The key attributes of the requirements ontology are business, technology, and constraints. Business requirements represent the needs of processes and activities for public service export; technology represents the technological requirements for the operation of public services; and constraints represent the business law, regulations, or cultural characteristics of the target country. The environment ontology is derived from case studies of target countries for public service operation. Key attributes of the environment ontology are user, requirements, and activity. A user includes stakeholders in public services, from citizens to operators and managers; the requirements attribute represents the managerial and physical needs during operation; the activity attribute represents business processes in detail. The enterprise ontology is introduced from a previous study, and its attributes are activity, organization, strategy, marketing, and time. The country ontology is derived from the demographic and geopolitical analysis of the target country, and its key attributes are economy, social infrastructure, law, regulation, customs, population, location, and development strategies. The priority list for target services for a certain country and/or the priority list for target countries for a certain public services are generated by a matching algorithm. These lists are used as input seeds to simulate the consortium partners, and government's policies and programs. In the simulation, the environmental differences between Korea and the target country can be customized through a gap analysis and work-flow optimization process. When the process gap between Korea and the target country is too large for a single corporation to cover, a consortium is considered an alternative choice, and various alternatives are derived from the capability index of enterprises. For financial packages, a mix of various foreign aid funds can be simulated during this stage. It is expected that the proposed ontology model and the business incubation platform can be used by various participants in the public service export market. It could be especially beneficial to small and medium businesses that have relatively fewer resources and experience with public service export. We also expect that the open and pervasive service architecture in a digital business ecosystem will help stakeholders find new opportunities through information sharing and collaboration on business processes.

• 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.