• 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 Sericultural and Entomological Science
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• v.25 no.1
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• pp.34-43
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• 1983

These studies have been carried out to find better locations for sericultural service regardless of the international silk market fluctuation in Korea. In order to acieve the purpose, various investigations and analyses have been carried out for more than four hundred sericultural communities to find out the main factors which caused to decrease in cocoon production in spite of a gloomy past silk market. Now, we believe that we have set up some fundamental guide lines in developing sound serviceable sericultural communities in Korea in case the government accepts the written advices, and the results obtained are as follows: 1. The Korean sericulture has been very prosperous from the 60's to the 70's. In 1976 the cocoon production was at its peak, reaching 41,704M/T from which its decline took place with annual averages of 18.5% for total cocoon production and 16.4% for mulberry field. These figures represent a quantitative decrease to one-third of the total amount in 1976. Since then, the Korean sericulture had continuously suffered from a shortage of raw silk resulting in a slow development of sericulture. At present, a steady development through all possible measures is great importance. 2. The downfall of the korean sericulture resulted from two factors of such as the external, which led to the decline in the price of raw silk at the international market and restrain of import and, the internal, resulting in the little increase of cocoon price and a comparatively lower benefits from the sericulture than from other cash crops. 3. The already established sericultural zone collapsed and then reorganized with the outstanding regional specialization so the decline in total cocoon production in the country. Based on the agricultural regions, 1980 cocoon production was very stable in the mountaineaus area of the east-south which used with intercropping. In this area there was small decline of 33% compare with that of the 1979, and with 70% decline in the dry field farming area of Kangwon Do. In an administrative districtwise, six counties beginning with Sanchnung county of Kyungsang Nam Do, showed less than 20% decline of cocoon production, sixteen counties beginning with Samchuck county of Kangwon Do marked above 80% decrease of cocoon production. In the smaller unit area-wise, there was a big difference among them. twenty-five myons rather increased and a hundrd fourty-three myons decreased above 80% of it. 4. The cocoon production was positively correlated with the decreasing percentage of cocoon production per household. It was also affected by the ratio of the mulberry field area to the total cultivated area per household and cocoon productivity per 10a. 5. Four hundred sixty-four villages in the seventeen counties were surveyed on the basis of farm management and techniques concerned ('80/'79), and then the results were evaluated by using of computer. These results are summarized as foolows: (1) Cocoon production per household There was no difference among the agricultural regions in cocoon production. The cocoon production per household in the comparatively stable villages increased from 100.8kg in 1979 to 122kg in 1981. Cocoon yield in the stable villages decreased by 20% of '81/'79. The cocoon production per house hold in while that of the unstable villages decreased by more than 40% from 102.9kg in 1979 to 82kg in 1981. (2) Cocoon yield per 10a mulberry field The cocoon yield per 10a was higher in the plain area than in the mountaineous area. The stable villages had an average of 73.4kg cocoon yield/10a while the unstabe ones had only an average of 55kg. (3) Adoption the mulberry branch rearing method The branch rearing method was more popular in the plain area than in the mountainous area. In the stable vilages adopted 24.2% in spring and 16.7% in autumn of 1979. In 1981 it shwed increases of 34.3% and 10.1% in the two seasons respectivly. However, the unstable villages showed 13.3% and 126% in both seasons, respectively. (4) The patterns of the combined management system in the sericultural farming The popular management system in the sericultural from was combined with rice and other cash crops, showing 55% of the total households surveyed. Fourteen percent of the households combined the management system with rice and other cash crops and 14% of the households combined with rice only. The villages wich earned less than 20% of the total income from the sericulture reached 81% of the total houscholds indicating that they were still far beyond a complete combination system. (5) Damage by agricultural chemicals The damage caused by agricultural chemicals was mainly due to the protection of rice against insectpests and diseases in the plain areas and took place mostly in the autumn season. The chemicals applied was 65% of Iiquid and 35% of powder forms and 35% of damage was from granulat form of the chemicals. The use of the granular chemicals was low because of high cost.