• 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.

• Journal of Global Scholars of Marketing Science
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• v.17 no.4
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• pp.51-89
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• 2007

INTRODUCTION Due to the high broadband internet penetration rate and its group-oriented culture, various types of online communities operate in Korea. This study use 'Uses and Gratification Approach, and argue that members' usage-needs satisfaction with brand community is an important factor for promoting community commitment. Based on previous studies identifying the effect of brand image on consumers' responses to various marketing stimuli, this study hypothesizes that brand image can be a moderate variable affecting the relationship between usage-needs satisfaction with brand community and members' commitment to brand community. This study analyzes the influence of usage-needs satisfaction on brand community commitment and how apparel brand image affects the relationships between usage-needs satisfactions and community commitments. The hypotheses of this study are proposed as follows. H1-3: The usage-needs satisfaction of apparel brand community (interest, transaction, relationship needs) influences emotional (H1), continuous (H2), and normative (H3) commitments to apparel brand communities. H4-6: Apparel brand image has a moderating effect on the relationship between usage-needs satisfaction and emotional (H4), continuous (H5), and normative (H6) commitments to apparel brand communities. METHODS Brand communities founded by non-company affiliates were excluded and emphasis was placed instead on communities created by apparel brand companies. Among casual apparel brands registered in 6 Korean portal sites in August 2003, a total of 9 casual apparel brand online communities were chosen, depending on the level of community activity and apparel brand image. Data from 317 community members were analyzed by exploratory factor analysis, moderated regression analysis, ANOVA, and scheffe test. Among 317 respondents answered an online html-type questionnaire, 80.5% were between 16 to 25 years old. There were a total of 150 respondents from apparel brand communities(n=3) recording higher-than-average brand image scores (Mean > 3.75) and a total of 162 respondents from apparel brand communities(n=6) recording lower-than-average brand image scores(Mean < 3.75). In this study, brand community commitment was measured by a 5-point Likert scale: emotional, continuous and normative commitment. The degree of usage-needs satisfaction (interest, transaction, relationship needs) was measured on a 5-point Likert scale. The level of brand image was measured by a 5-point Likert scale: strength, favorability, and uniqueness of brand associations. RESULTS In the results of exploratory factor analysis, the three usage-needs satisfactions with brand community were classified as interest, transaction, and relationship needs. Brand community commitment was also divided into the multi-dimensional factors: emotional, continuous, and normative commitments. The regression analysis (using a stepwise method) was used to test the influence of 3 independent variables (interest-needs satisfaction, transaction-needs, and relationship-needs satisfactions) on the 3 dependent variables (emotional, continuous and normative commitments). The three types of usage-needs satisfactions are positively associated with the three types of commitments to apparel brand communities. Therefore, hypothesis 1, 2, and 3 were significantly supported. Moderating effects of apparel brand image on the relationship between usage-needs satisfaction and brand community commitments were tested by moderated regression analysis. The statistics result showed that the influence of transaction-needs on emotional commitment was significantly moderated by apparel brand image. In addition, apparel brand image had moderating effects on the relationship between relationship-needs satisfaction and emotional, continuous and normative commitments to apparel brand communities. However, there were not significant moderate effects of apparel brand image on the relationships between interest-needs satisfaction and 3 types of commitments (emotional, continuous and normative commitments) to apparel brand communities. In addition, the influences of transaction-needs satisfaction on 2 types of commitments (continuous and normative commitments) were not significantly moderated by apparel brand image. Therefore, hypothesis 4, 5 and 6 were partially supported. To explain the moderating effects of apparel brand image, four cross-tabulated groups were made by averages of usage-needs satisfaction (interest-needs satisfaction avg. M=3.09, transaction-needs satisfaction avg. M=3.46, relationship-needs satisfaction M=1.62) and the average apparel brand image (M=3.75). The average scores of commitments in each classified group are presented in Tables and Figures. There were significant differences among four groups. As can be seen from the results of scheffe test on the tables, emotional commitment in community group with high brand image was higher than one in community group with low brand image when transaction-needs satisfaction was high. However, when transaction-needs satisfaction was low, there was not any difference between the community group with high brand image and community group with low brand image regarding emotional commitment to apparel brand communities. It means that emotional commitment didn't increase significantly without high satisfaction of transaction-needs, despite the high apparel brand image. In addition, when apparel brand image was low, increase in transaction-needs did not lead to the increase in emotional commitment. Therefore, the significant relationship between transaction-needs satisfaction and emotional commitment was found in only brand communities with high apparel brand image, and the moderating effect of apparel brand image on this relationship between two variables was found in the communities with high satisfaction of transaction-needs only. Statistics results showed that the level of emotional commitment is related to the satisfaction level of transaction-needs, while overall response is related to the level of apparel brand image. We also found that the role of apparel brand image as a moderating factor was limited by the level of transaction-needs satisfaction. In addition, relationship-needs satisfaction brought significant increase in emotional commitment in both community groups (high and low levels of brand image), and the effect of apparel brand image on emotional commitment was significant in both community groups (high and low levels of relationship-needs satisfaction). Especially, the effect of brand image was greater when the level of relationship-needs satisfaction was high. in contrast, increase in emotional commitment responding to increase in relationship-needs satisfaction was greater when apparel brand image is high. The significant influences of relationship-needs satisfaction on community commitments (continuous and normative commitments) were found regardless of apparel brand image(in both community groups with low and high brand image). However, the effects of apparel brand image on continuous and normative commitments were found in only community group with high satisfaction level of relationship-needs. In the case of communities with low satisfaction levels of relationship needs, apparel brand image marginally increases continuous and normative commitments. Therefore, we could not find the moderating effect of apparel brand image on the relationship between relationship-needs satisfaction and continuous and normative commitments in community groups with low satisfaction levels of relationship needs, CONCLUSIONS AND IMPLICATIONS From the results of this study, we draw several conclusions; First, the increases in usage-needs satisfactions through apparel brand communities result in the increases in commitments to apparel brand communities, wheres the degrees of such relationship depends on the level of apparel brand image. That is, apparel brand image is a moderating factor strengthening the relationship between usage-needs satisfaction and commitment to apparel brand communities. In addition, the effect of apparel brand image differs, depending on the level and types of community usage-needs satisfactions. Therefore, marketers of apparel brand companies must determine the appropriate usage-needs, depending on the type of commitment they wish to increase and the level of their apparel brand image, to promote member's commitments to apparel brand communities. Especially, relationship-needs satisfaction was very important factor for increasing emotional, continuous and normative commitments to communities. However the level of relationship-needs satisfaction was lower than interest-needs and transaction-needs. satisfaction. According to previous study on apparel brand communities, relationship-need satisfaction was strongly related to member's intention of participation in their communities. Therefore, marketers need to develope various strategies in order to increase the relationship- needs as well as interest and transaction needs. In addition, despite continuous commitment was higher than emotional and normative commitments, all types of commitments to apparel brand communities had scores lower than 3.0 that was mid point in 5-point scale. A Korean study reported that the level of members' commitment to apparel brand community influenced customers' identification with a brand and brand purchasing behavior. Therefore, marketers should try to increase members' usage-needs satisfaction and apparel brand image as the necessary conditions for bringing about community commitments. Second, marketers should understand that they should keep in mind that increasing the level of community usage needs (transaction and relationship) is most effective in raising commitment when the level of apparel brand image is high, and that increasing usage needs (transaction needs) satisfaction in communities with low brand image might not be as effective as anticipated. Therefore, apparel companies with desirable brand image such as luxury designer goods firms need to create formal online brand communities (as opposed to informal communities with rudimentary online contents) to satisfy transaction and relationship needs systematically. It will create brand equity through consumers' increased emotional, continuous and normative commitments. Even though apparel brand is very famous, emotional commitment to apparel brand communities cannot be easily increased without transaction-needs satisfaction. Therefore famous fashion brand companies should focus on developing various marketing strategies to increase transaction-needs satisfaction.