• 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 Energy Engineering
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• v.29 no.2
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• pp.68-78
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• 2020

According to the new climate change agreement, technology development to reduce greenhouse gases is actively conducted worldwide, and research on energy efficiency improvement in the field of power generation and transmission and distribution is underway [1,2]. Economic analysis of the operation method of storing and supplying surplus electricity using energy storage devices, and using energy storage devices as a frequency adjustment reserve power in regional cogeneration plants has been reported as the most profitable operation method [3-7]. Therefore, this study conducted an economic analysis for the installation of energy storage devices in the combined heat and power plant in the Czech Republic. The most important factor in evaluating the economics of battery energy storage devices is the lifespan, and the warranty life is generally 10 to 15 years, based on charging and discharging once a day. For the simulation, the ratio of battery and PCS was designed as 1: 1 and 1: 2. In general, the primary frequency control is designed as 1: 4, but considering the characteristics of the cogeneration plant, it is set at a ratio of up to 1: 2, and the capacity is simulated at 1MW to 10MW and 2MWh to 20MWh according to each ratio. Therefore, life was evaluated based on the number of cycles per year. In the case of installing a battery energy storage system in a combined heat and power plant in the Czech Republic, the payback period of 3MW / 3MWh is more favorable than 5MW / 5MWh, considering the local infrastructure and power market. It is estimated to be about 3 years or 5 years from the simple payback period considering the estimated purchase price without subsidies. If you lower the purchase price by 50%, the purchase cost is an important part of the cost for the entire lifetime, so the payback period is about half as short. It can be, but it is impossible to secure profitability through the economy at the scale of 3MWh and 5MWh. If the price of the electricity market falls by 50%, the payback period will be three years longer in P1 mode and two years longer in P2 and P3 modes.

• KDI Journal of Economic Policy
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• v.12 no.2
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• pp.81-94
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• 1990

Illegal transactions such as blackmarketing and smuggling allegedly result from too restrictive trade policies. A recent U.S. Senate hearing on the blackmarketing of American goods imported into Korea for the purpose of supporting United States troops and their dependents stationed in Korea concluded with the allegation that Korea's highly restrictive trade practices are responsible for the emergence of the black market. It has also suggested that the removal of such restrictive trade policies would eliminate black market activities. This study addresses the relationship between trade policy and blackmarketing by investigating whether trade liberalization results in the reduction of illegal transactions, and whether the eradication of blackmarketing indeed improves social welfare. When both legally imported goods and illegally exchanged items command the same price, trade liberalization, meaning a decrease in tariff rates or an increase in import quotas, will increase the quantity of legal imports at the expense of illegally transacted goods on the black market. But the price of legally imported goods usually differs from that of illegally sold ones. In this case, a change in the relative prices of these two groups of goods due to a change in trade policy will give rise to income, as well as substitution, effects. Initially, a decrease in the import price due to a decrease in import tax rates or an increase in the allotted quota will reduce illegal transactions, since the decrease in the import price will induce the substitution of legal imports for illegally exchanged, but otherwise, identical goods. On the other hand, the demand for the illegally transacted goods will rise, because of the income effect of the reduced import price. Thus, assuming the positive income effect overwhelms the negative substitution effect, the demand for illegal goods will increase, thwarting the reduction of blackmarketing through trade liberalization. Yet, stepping up the enforcement measures which are geared to preventing blackmarketing itself will drastically reduce the extent of illegal transactions, since it increases the cost of blackmarketing and hence the price of the illegally transacted goods. What this study suggests is that the emergence of the black market in Korea should be attributed more to the excessive supply of duty-free goods imported through U.S. commissaries and exchanges than to the excessive demand for foreign goods. On the other hand, blackmarketing, in most cases, improves economic welfare, since it constitutes an increase in the "actual" amount of imported goods. Suppressing blackmarketing through stepped-up enforcement methods is beneficial only when the substitution effect of the legally transacted goods resulting from the increase in the price of the illegal goods prevails, since the increase in the demand for legal imports must override the decrease in the demand for black market goods as well as the negative income effect.

• Journal of Climate Change Research
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• v.5 no.1
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• pp.1-12
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• 2014

With continued economic growth, Korea has seen an increase in the nighttime activities of its citizens as hours of activity have extended into night. There is an increasing trend in energy consumption related to citizens' nighttime activities. In order to analyze ideas for an efficient replacement of the power consumption of streetlights and for profit generation by applying grid-type solar systems, this study used an RETScreen model. Through energy analysis and cost analysis, the application benefit and viability of grid-type solar street light systems were analyzed. With analysis result of a total weekly power generation of 114 kWh via a grid-connected solar streetlight system, it was shown that the net present value of a grid-connected solar street light system is 155,362 KRW, which would mean a payback period of about 5.2 years, and as such, it was shown that profit could be generated after about 6 years. In addition, if the grid-connected solar power generation system proposed by this study is to be applied, it was shown that 401,935 KRW in profit could be generated after the 20-year useful life set for the solar system. In addition, the sensitivity analysis was performed taking into account the price fluctuations of SMP, maintenance. As a result, a payback period has increased by 1~2 years, and there were no significant differences. Because the most important factor that affect the economic analysis is the cost of supply certification of renewable energy, a stable sales and acquisition of this certification are very important. the Seoul-type Feed in Tariff(FIT) connected to other institutions will enable steady sales by confirming to purchase the certification for 12 years. Therefore, if those issues mentioned above are properly reflected, Central-grid PV system project will be able to perform well in the face of unfavorable condition of solar PV installation.

• Journal of Korea Port Economic Association
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• v.37 no.3
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• pp.117-128
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• 2021

In order for the users (shipping firms and shippers) and suppliers (stevedoring firms) in the container terminal industry to win-win, it is necessary to have some appropriate diverse market conditions for the industry. This study analyses the basic conditions and demand and supply characteristics of the industry and investigates the market performance of Busan container ports. First, this article analyses the basic characteristics of demand and supply. As the demand characteristics, there are five ones such as 1) exogeneity of demand, 2) function as export/import transportation and hub for transshipment, 3) increase of users' bargaining power, 4) high substituting elasticity, 5) reduction of volume growth. As the supply characteristics, there are seven ones such as 1) inelasticity of supply, 2) homogeneity of stevedoring services, 3) over-supply, 4) adoption of cutting-edge stevedoring technology, 5) scale economy and impossibility of storage, 6) labor market rigidity, 7) enhancing port's role in SCM. In addition, this study conducts the so-called structure-conduct-performance analysis. For the structure analysis, 1) lacks of scale economy in stevedoring companies, 2) high entry barrier, 3) strengthening of shipping firms' bargaining power, 4) transitory permission scheme for tariff are analyzed. For the conduct analysis, 1) price discrimination between export/import and transshipment, 2) mid-term length of terminal use contract, 3) continuous investment in equipment, 4) low level of cooperation among terminal operating firms are derived. For the performance analysis, 1) inequality in profitability, 2) reduction of export/import cost, 3) delay in adopting cutting-edge technology, 4) idle equipment are analyzed. Following this logical flow, the hypothesis that the market structure influences the market conduct is tested based on the actual dataset. As a future agenda in the conclusion, this article recommends the so-called port industrial policy.

• The Korean Journal of Air & Space Law and Policy
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• v.32 no.1
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• pp.83-138
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• 2017

Korea-China FTA entered into force on the 20th of December 2015, and one year elapsed after its effectuation as the FTA with China, our country's largest trading partner. Therefore, this study looks at the trends of air transport trade between Korea and China, and examines the contents of concessions to the air transport services sector in Korea-China FTA, and analyzes the impact on the air transport sector by Korea-China FTA, and proposes our country's aviation policy direction in order to respond to such impact. In 2016 the trends of air transport trade between Korea and China are as follows : The export amount of air transport trade to China was 40.03 billion dollars, down by 9.3% from the last year, and occupied 32.2% of the total export amount to China. The import amount of air transport trade from China was 24.26 billion dollars, down by 9.1% from the last year, and occupied 27.7% of the total import amount from China. The contents of concessions to the air transport services sector in Korea-China FTA are as follows : China made concessions to the aircraft repair and maintenance services and the computer reservation system services with limitations on market access and national treatment in the air transport services sector of the China Schedule of Specific Commitments of Korea-China FTA Chapter 8 Annex. Korea made concessions to the computer reservation system services, selling and marketing of air transport services, and aircraft repair and maintenance without limitations on market access and national treatment in the air transport services sector of the Korea Schedule of Specific Commitments of Korea-China FTA Chapter 8 Annex. The impact on the air transport sector by Korea-China FTA are as follows : As for the impact on the air passenger market, in 2016 the arrival passengers of the international flight from China were 9.96 million, up by 20.6% from the last year, and the departure passengers to China were 9.90 million, up by 34.8% from the last year. As for the impact on the air cargo market, in 2016 the exported goods volumes of air cargo to China were 105,220.2 tons, up by 6.6% from the last year, and imported goods volumes from China were 133,750.9 tons, up by 12.3% from the last year. Among the major items of exported air cargo to China, the exported goods volumes of benefited items in the Tariff Schedule of China of Korea-China FTA were increased, and among the major items of imported air cargo from China, the imported goods volumes of benefited items in the Tariff Schedule of Korea of Korea-China FTA were increased. As for the impact on the logistics market, in 2016 the handling performance of exported air cargo to China by domestic forwarders were 119,618 tons, down by 2.1% from the last year, and the handling performance of imported air cargo from China were 79,430 tons, down by 4.4% from the last year. In 2016 the e-commerce export amount to China were 109.16 million dollars, up by 27.7% from the last year, and the e-commerce import amount from China were 89.43 million dollars, up by 72% from the last year. The author proposes the aviation policy direction of Korea according to Korea-China FTA as follows : First, the open skies between Korea and China shall be pushed ahead. In June 2006 Korea and China concluded the open skies agreement within the scope of the third freedom and fourth freedom of the air for passenger and cargo in Sandong Province and Hainan Province of China, and agreed the full open skies of flights between the two countries from the summer season in 2010. However, China protested against the interpretation of the draft of the memorandum of understanding to the air services agreement, therefore the further open skies did not take place. Through the separate aviation talks with China from Korea-China FTA, the gradual and selective open skies of air passenger market and air cargo market shall be pushed ahead. Second, the competitiveness of air transport industry and airport shall be secured. As for the strengthening methods of the competitiveness of Korea's air transport industry, the support system for the strengthening of national air carriers' competitiveness shall be prepared, and the new basis for competition of national air carriers shall be made, and the strategic network based on national interest shall be built. As for the strengthening methods of the competitiveness of Korea's airports, particularly Incheon Airport, the competitiveness of the network for aviation demand creation shall be strengthened, and the airport facilities and safety infrastructure shall be expanded, and the new added value through the airport shall be created, and the world's No.1 level of services shall be maintained. Third, the competitiveness of aviation logistics enterprises shall be strengthened. As for the strengthening methods of the competitiveness of Korea's aviation logistics enterprises, as the upbringing strategy of higher added value in response to the industry trends changes, the new logistics market shall be developed, and the logistics infrastructure shall be expanded, and the logistics professionals shall be trained. Additionally, as the expanding strategy of global logistics market, the support system for overseas investment of logistics enterprises shall be built, and according to expanding the global transport network, the international cooperation shall be strengthened, and the network infrastructure shall be secured. As for the strengthening methods of aviation logistics competitiveness of Incheon Airport, the enterprises' demand of moving in the logistics complex shall be responded, and the comparative advantage in the field of new growth cargo shall be preoccupied, and the logistics hub's capability shall be strengthened, and the competitiveness of cargo processing speed in the airport shall be advanced. Forth, in the subsequent negotiation of Korea-China FTA, the further opening of air transport services sector shall be secured. In the subsequent negotiation being initiated within two years after entry into force of Korea-China FTA, it is necessary to ask for the further opening of the concessions of computer reservation system services, and aircraft repair and maintenance services in which the concessions level of air transport services sector by China is insufficient compared to the concessions level in the existing FTA concluded by China. In conclusion, in order to respond to the impact on Korea's air passenger market, air cargo market and aviation logistics market by Korea-China FTA, the following policy tasks shall be pushed ahead : Taking into consideration of national air carriers' competitiveness and nation's benefits, the gradual and selective open skies shall be pushed ahead, and the support system to strengthen the competitiveness of air transport industry and airport shall be built, and entry into aviation logistics market by logistics enterprises shall be expanded, and the preparations to ask for the further opening of air transport services sector, low in the concessions level by China shall be made.