• 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 the Korean Society of Costume
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• v.35
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• pp.45-66
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• 1997

This thesis is a study on the kaftan styles iin Asia. The purpose of he study was to examine the origin o the kaftan concentrating on the history and cultural backgrounds of nomads in he Western Central and North Eastern Asia. Secondly for more thorough study and expla-nation on how these kaftans contributed to East-West trade along the silk road. wall paintings and miniature illuminations along Oasis roads persia and Saracen period were compared, Also real kaftans were compared and analyzed the characteristics of Western (Turkey palestine) Central(Kazakistan Uz-bekistan Tadzhistan Qyrgyztan Turkmenistan) and the North Eastern Asian(Mongol) area. Thirdly an attempt has been made to provide the North Eastern Asian(Mongol) area. Thirdly an attempt has been made to provide the style classifications according to their peculiarities of the various kaftans as well as how kaftan gave important influences on custumes of different religious sects. The kaftan is a long coat-like garment with front openings fastened with long sash having an extra long sleeves which were worn by middle and high class nomadics throughout the West Central and North Eastern Asia This type of kaftans were a basic clothing for nomadics since they were constantly moving fromone to another areas on their horse back riding. They also wore tight trousers with boots. Kaftans seem to be originated from nomads of Steppe around B.C. 800 On B. C 400 west asian areas such as Solokha Kul-oba Kulogan had pictures sculptues on vases showing kaftans of half coat type length with front opening tied with band. Also the materials used were the products of animals such as wool or felt with animal designs showing Scythian nomads. In the North Eastern Asia Hsiung-Nu were active in Kazakha North Altai and Mongol The Clothing and fabrics exfavated near Noin-ula Pazyrik showed many samples of kaftan with trousers with other interment be-longings with a corpse around B.C 300 to A. D 100 when trades along the silk roads were proven by many historians Kaftans excavated in this area wore red front opening silk materials which suggesting settling down of nomads. in he central Asia Dol-gull near Altai mountain area were mainly miners who later had many trades with Persia and Bizantine. After Dol-gull Bezeklik temple Samarkant Kizil cow Budda sculture wall paintings of Astana tomb showed typical kaftan of this re-gion. These were both hip covered length as well as long coat with narrow sleeves. Es-pecially they had different color band fron the main kaftan with grogeously and splendously designed silk. In perusia during A. D 1400 to 1600 minia-ture illumination showed kaftan as a high class symbol more than clothing purpose. They had best quality silk with extra long sleeves draping and had a layers of kaftans one on top of anther as a symbol of wealth These Kaftans with different colors and designs were even more beautiful with their effective combinations and contrast of colors. On the other hand the lower class common people and servants wore simple kaftan with the front part of the kaftan were slipped into the belt in order to be more active and con-venient to work, The real kaftans discovered at Topkapi Saray palace of Turkey from A. D 1300 to 1900 were also compared. These kaftans were very numerous in numbers as well as designs The materials and designs used were also vari-ous such as Chinese to Italian silk. The shaped and pattern itself were not much different from the previous nomad's Kaftans. The Palestian kaftans remained were from the beginning of 19th and 20th century. Since this area is hot and dry desert they used black and navy blue colors mostly in order to exclude the sun lights. The patterns used were similar to Nomads and Bedouin with cross stiches and patch work decorations. In the central Asia they had similar life style and natural environmental cnditions with Turkish tribe which resulted in similar kaftan styles as nomads. Mongols conserved basic patterns of kaftan since Cinggis Khan with deep folding in order to keep warm. At last the kaftans studided in this thesis were classified in to four such as half coat long coat jacket and vest style. A pattern used in the Central Asia were zigzag and ani-mal design whereas in the West Asia were floral plant arabesk and circle pattern. As I discussed previously kaftan styles of nomads in the Asia maintained its basic pat-tern throughout the history except slight changes in color gusset sleeve shapes. These slight changes were made according to the need to adapt the need of environmental natu-ral conditions, The reason for aboriginality of kaftan in Asia was its simplicity and con-venience Most interesting fact is that for all these years Mongols are still wearing kaftan in their life ensuring us that they art the preserves of old kaftan. Since this thesis dealt enormous Asian regions I had a limitation of not being able to cover the Far Esatern asian areas such as Korea China and Japan how these kaftans were influenced in their clothing history as well as Eastern and Western culture. This topic along with the studies on materials and designs of patterns of kaftan will be another research project in the future.

• Korean Journal of Heritage: History & Science
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• v.42 no.2
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• pp.62-85
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• 2009

The Nam-Hae Sin-sa, the South Sea shrine in Yeong-Am, Korea was a national institution for public peace and bliss, was excavated in 2000, and the shrine and the 3-way-gate were reconstructed in 2001. Hae Sin-sa, the Sea shrine is a place for religious service separated into the Nam-Hae Sin-sa, the Dong-Hae Myo, and the Seo-Hae Dan. The Dong-Hae Myo was reconstructed, but restored shrine and 3-way-gate of the Nam-Hae Sin-sa is not perfect in comparison with excavation plan in 2000, therefore new reconstruction was researched through the related literature, the analysis of historical maps and excavation results, the interview with the concerned people and the case study. This research defines the analysis of the Plan of the Nam-Hae Sin-sa Reconstruction as follows. 1. The Nam-Hae Sin-sa was the institution for religious service operated by national direct management, represents the shrine for public peace and bliss on the Mountain, the Sea, and the River. Especially the Nam-Hae Sin-sa had an important position on the pivot of international trade with China and Japan, and had a role of main shrine with another one in the Mt. Ji-ri San. 2. The name of the Sea shrine was called as Nam-Hae Sin-sa(the South Sea shrine), Dong-Hae Myo(the East Sea shrine), Seo-Hae Dan(the West Sea shrine). But the name of the South Sea shrine had changed in the early period of Chosun as Nam-Hae Sin-sa to the later Chosun as Nam-Hae Dang through the research of related literature and historical map. Such as the Seo-Hae Dan, it was constructed for the Dan, the flat raised-floor without buildings, and changed to the type of Sa-Dang with addition of buildings. 3. The historical map of Hae Sin-sa informs the types of the roof, the Mat-bae roof was used in the Dong-Hae Myo, but the Pal-jak roof was showed in the Seo-Hae Dan and the Nam-Hae Sin-sa. 4. According to the analysis of Yong-Ch'uck the unit length, Nam-Hae Sin-sa was reconstructed in the period of Koryo on large scale, but it was restored in the Chosun on middle scale. And the Unit of Yong Ch'uck was changed into Yeong-jo Ch'uck in the period of Chosun. 5. As the results, The Plan of the Nam-Hae Sin-sa Reconstruction designed the new shrine into the 3 Kan front and the 2 Kan side with 3:2 scale. An-ch'o-gong with Yong-du and Yong Mi the ornaments represents head and tail of dragon, the Un-gong and the ornament of Pa-ryun-dae-gong in the building, and the Ch'ung-ryang of the Yong-du show the image of the institution for religious service for the god of the sea who look like dragon. The inner gate building and the main entrance were designed as same plan and scale as Hyang-gyo, the Korean Traditional School and Shrine of Confucianism, on the basis of results of excavation. Raise the 3-tall gate of the main entrance with harmony of the scale and the shape, because the side of gate building has the Mat-bae roof. 6. This research shows that Plan of the Nam-Hae Sin-sa Reconstruction is composed into shrine space and reservation space from the main entrance to inner gate and shrine like Jung-ak Dan in the Mt. Gye-ryong San, and it also informs the well in the west side of Sin-sa is an important factor of the plan of shrine architecture.

• The Korean Journal of Air & Space Law and Policy
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• v.28 no.2
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• pp.295-347
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• 2013

Korea launched the science satellite by the first launch vehicle Naro-ho(KSLV-1) at the Naro Space Center located at Oinarodo, Cohenggun Jellanamdo in August, 2009 and October, 2010. However, the first and second launch failed. At last, on January 30, 2013 the third launch of the launch vehicle Naro-ho has successfully launched and the Naro science satellite penetrated into the space orbit. Owing to the succeed of the launch of Naro-ho, Korea joined the space club by the eleventh turn following the United States, Russia, Japan and China. The United Nations adopted the Outer Space Treaty of 1967, the Rescue Agreement of 1968, the Liability Convention of 1972, the Regislation Convention of 1976, and Moon Agreement of 1979. Korea ratified the above space-related treaties except the Moon Agreement. Such space-related treaties regulate the international liability for the space activity by the launching state of the space object. Especially the Outer Space Treaty regulates the principle concerning the state's liability for the space activity. Each State Party to the Treaty that launches or procures the launching of an object into outer space is internationally liable for damage to another State Party or to its natural or judicial persons by such object or its component parts on the earth, in air space or in outer space. Under the Liability Convention, a launching state shall be absolutely liable to pay compensation for damage caused by its space object on the surface of the earth or to aircraft in flight. The major nations of the world made national legislations to observe the above space-related treaties, and to promote the space development, and to regulate the space activity. In Korea, the United States, Russia and Japan, the national space-related legislation regulates the government's liability of the launching state of the space object. The national space-related legislations of the major nations are as follows : the Outer Space Development Promotion Act and Outer Space Damage Compensation Act of Korea, the National Aeronautic and Space Act and Commercial Space Launch Act of the United States, the Law on Space Activity of Russia, and the Law concerning Japan Aerospace Exploration Agency and Space Basic Act of Japan. In order to implement the government's liability of the launching state of space object under space-related treaties and national legislations, and to establish the standing as a strong space nation, Korea shall improve the space-related policy, laws and system as follows : Firstly, the legal system relating to the space development and the space activity shall be maintained. For this matter, the legal arrangement and maintenance shall be made to implement the government's policy and regulation relating to the space development and space activity. Also the legal system shall be maintained in accordance with the elements for consideration when enacting the national legislation relevant to the peaceful exploration and use of outer space adopted by UN COPUOS. Secondly, the liability system for the space damage shall be improved. For this matter, the articles relating to the liability for the damage and the right of claiming compensation for the expense already paid for the damage in case of the joint launch and consigned launch shall be regulated newly. Thirdly, the preservation policy for the space environment shall be established. For this matter, the consideration and preservation policy of the environment in the space development and use shall be established. Also the rule to mitigate the space debris shall be adopted. Fourthly, the international cooperation relating to the space activity shall be promoted. For this matter, the international cooperation obligation of the nation in the exploration and use of outer space shall be observed. Also through the international space-related cooperation, Korea shall secure the capacity of the space development and enter into the space advanced nation.