• 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 Distribution Research
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• v.17 no.2
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• pp.63-92
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• 2012

This study investigated consumer intention to use a location-based mobile shopping service (LBMSS) that integrates cognitive and affective responses. Information relevancy was integrated into pleasure-arousal-dominance (PAD) emotional state model in the present study as a conceptual framework. The results of an online survey of 335 mobile phone users in the U.S. indicated the positive effects of arousal and information relevancy on pleasure. In addition, there was a significant relationship between pleasure and intention to use a LBMSS. However, the relationship between dominance and pleasure was not statistically significant. The results of the present study provides insight to retailers and marketers as to what factors they need to consider to implement location-based mobile shopping services to improve their business performance. Extended Abstract : Location aware technology has expanded the marketer's reach by reducing space and time between a consumer's receipt of advertising and purchase, offering real-time information and coupons to consumers in purchasing situations (Dickenger and Kleijnen, 2008; Malhotra and Malhotra, 2009). LBMSS increases the relevancy of SMS marketing by linking advertisements to a user's location (Bamba and Barnes, 2007; Malhotra and Malhotra, 2009). This study investigated consumer intention to use a location-based mobile shopping service (LBMSS) that integrates cognitive and affective response. The purpose of the study was to examine the relationship among information relevancy and affective variables and their effects on intention to use LBMSS. Thus, information relevancy was integrated into pleasure-arousal-dominance (PAD) model and generated the following hypotheses. Hypothesis 1. There will be a positive influence of arousal concerning LBMSS on pleasure in regard to LBMSS. Hypothesis 2. There will be a positive influence of dominance in LBMSS on pleasure in regard to LBMSS. Hypothesis 3. There will be a positive influence of information relevancy on pleasure in regard to LBMSS. Hypothesis 4. There will be a positive influence of pleasure about LBMSS on intention to use LBMSS. E-mail invitations were sent out to a randomly selected sample of three thousand consumers who are older than 18 years old and mobile phone owners, acquired from an independent marketing research company. An online survey technique was employed utilizing Dillman's (2000) online survey method and follow-ups. A total of 335 valid responses were used for the data analysis in the present study. Before the respondents answer any of the questions, they were told to read a document describing LBMSS. The document included definitions and examples of LBMSS provided by various service providers. After that, they were exposed to a scenario describing the participant as taking a saturday shopping trip to a mall and then receiving a short message from the mall. The short message included new product information and coupons for same day use at participating stores. They then completed a questionnaire containing various questions. To assess arousal, dominance, and pleasure, we adapted and modified scales used in the previous studies in the context of location-based mobile shopping service, each of the five items from Mehrabian and Russell (1974). A total of 15 items were measured on a seven-point bipolar scale. To measure information relevancy, four items were borrowed from Mason et al. (1995). Intention to use LBMSS was captured using two items developed by Blackwell, and Miniard (1995) and one items developed by the authors. Data analyses were conducted using SPSS 19.0 and LISREL 8.72. A total of usable 335 data were obtained after deleting the incomplete responses, which results in a response rate of 11.20%. A little over half of the respondents were male (53.9%) and approximately 60% of respondents were married (57.4%). The mean age of the sample was 29.44 years with a range from 19 to 60 years. In terms of the ethnicity there were European Americans (54.5%), Hispanic American (5.3%), African-American (3.6%), and Asian American (2.9%), respectively. The respondents were highly educated; close to 62.5% of participants in the study reported holding a college degree or its equivalent and 14.5% of the participants had graduate degree. The sample represents all income categories: less than $24,999 (10.8%), $25,000-$49,999 (28.34%), $50,000-$74,999 (13.8%), and $75,000 or more (10.23%). The respondents of the study indicated that they were employed in many occupations. Responses came from all 42 states in the U.S. To identify the dimensions of research constructs, Exploratory Factor Analysis (EFA) using a varimax rotation was conducted. As indicated in table 1, these dimensions: arousal, dominance, relevancy, pleasure, and intention to use, suggested by the EFA, explained 82.29% of the total variance with factor loadings ranged from .74 to .89. As a next step, CFA was conducted to validate the dimensions that were identified from the exploratory factor analysis and to further refine the scale. Table 1 exhibits the results of measurement model analysis and revealed a chi-square of 202.13 with degree-of-freedom of 89 (p =.002), GFI of .93, AGFI = .89, CFI of .99, NFI of .98, which indicates of the evidence of a good model fit to the data (Bagozzi and Yi, 1998; Hair et al., 1998). As table 1 shows, reliability was estimated with Cronbach's alpha and composite reliability (CR) for all multi-item scales. All the values met evidence of satisfactory reliability in multi-item measure for alpha (>.91) and CR (>.80). In addition, we tested the convergent validity of the measure using average variance extracted (AVE) by following recommendations from Fornell and Larcker (1981). The AVE values for the model constructs ranged from .74 through .85, which are higher than the threshold suggested by Fornell and Larcker (1981). To examine discriminant validity of the measure, we again followed the recommendations from Fornell and Larcker (1981). The shared variances between constructs were smaller than the AVE of the research constructs and confirm discriminant validity of the measure. The causal model testing was conducted using LISREL 8.72 with a maximum-likelihood estimation method. Table 2 shows the results of the hypotheses testing. The results for the conceptual model revealed good overall fit for the proposed model. Chi-square was 342.00 (df = 92, p =.000), NFI was .97, NNFI was .97, GFI was .89, AGFI was .83, and RMSEA was .08. All paths in the proposed model received significant statistical support except H2. The paths from arousal to pleasure (H1: ${\ss}$=.70; t = 11.44), from information relevancy to intention to use (H3 ${\ss}$ =.12; t = 2.36), from information relevancy to pleasure (H4 ${\ss}$ =.15; t = 2.86), and pleasure to intention to use (H5: ${\ss}$=.54; t = 9.05) were significant. However, the path from dominance to pleasure was not supported. This study investigated consumer intention to use a location-based mobile shopping service (LBMSS) that integrates cognitive and affective responses. Information relevancy was integrated into pleasure-arousal-dominance (PAD) emotional state model as a conceptual framework. The results of the present study support previous studies indicating that emotional responses as well as cognitive responses have a strong impact on accepting new technology. The findings of this study suggest potential marketing strategies to mobile service developers and retailers who are considering the implementation of LBMSS. It would be rewarding to develop location-based mobile services that integrate information relevancy and which cause positive emotional responses.