• Title/Summary/Keyword: Transaction Tax

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The Effect of Ownership Structure on Transfer Pricing Decisions: Evidence from Foreign Direct Investments in Vietnam

  • TRAN, Quoc Thinh;TRAN, Mai Uoc;LUU, Chi Danh
    • The Journal of Asian Finance, Economics and Business
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    • v.8 no.12
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    • pp.183-189
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    • 2021
  • Transfer pricing is a matter of concern for countries. It affects the interests of the parties involved in the commercial transaction. Through manipulation of prices in transactions, businesses take advantage of tax rates in a country to adjust profits for economic gain. This affects the fairness and rationality of economic transactions between related parties. The article uses a two-year time series from 2018 to 2019 of 50 foreign direct investment enterprises in Vietnam. The article uses ordinary least squares to test the hypotheses of the research model. The article uses four independent variables related to ownership structure affecting transfer pricing decisions including total ownership, organization ownership, concentration ownership, and area ownership. Research results show that two variables have a positive influence on transfer pricing decisions including total ownership and organization ownership. Organization ownership has a higher degree of influence than total ownership. To be able to control transaction activities related to transfer pricing, Vietnam's state management agencies need to pay attention to perfecting the legal framework based on supplementing and amending regulations related to transfer pricing. Legal regulations need to be regulated based on international common practices to ensure uniformity on a global scale.

Study on the Problems of Korean GAAP and Tax Regulations on the Merge Transactions ("기업인수.합병 등에 관한 회계처리준칙" 및 관련 세법 규정의 문제점)

  • Shin, Hyun-Geol
    • Korean Business Review
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    • v.17 no.2
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    • pp.1-23
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    • 2004
  • Since revision of Korean GAAP on the merge transaction in 1999, the few studies on the problems of the GAAP or on the inconsistency of GAAP and regarding tax regulations have been performed. The objective of this study is to understand the present state of the merge transactions, to find out the problems on the regarding GAAP and tax regulations, and to suggest the method to improve them. Among the 69 merge transactions of the listed and registered companies for the recent 3 years, 67 merge transactions are reported as the purchase transactions and 2 transactions as the pooling of interest. And 11 transactions occurred between parents and subsidiaries. I investigate the sufficiency of the foot disclosures on the merge transactions, I find out that the disclosure on the amortization of the negative goodwill are not sufficient, and several transactions are not recorded in conformity with GAAP. This paper indicates the problems on the GAAP as follows: the complicated and irrational method of amortization of the negative goodwill, the valuation of the stocks acquired before the merge, the inconsistent adjustments to purchase consideration contingent on future events, and the valuation of the merge between the parents and subsidiaries. And the problems on the tax regulations are as follows: tax deferment of the income from merge valuation, the ambiguous definitions of the fair value, and stock dividend of the income from merge valuation.

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Classification of Parent Company's Downward Business Clients Using Random Forest: Focused on Value Chain at the Industry of Automobile Parts (랜덤포레스트를 이용한 모기업의 하향 거래처 기업의 분류: 자동차 부품산업의 가치사슬을 중심으로)

  • Kim, Teajin;Hong, Jeongshik;Jeon, Yunsu;Park, Jongryul;An, Teayuk
    • The Journal of Society for e-Business Studies
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    • v.23 no.1
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    • pp.1-22
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    • 2018
  • The value chain has been utilized as a strategic tool to improve competitive advantage, mainly at the enterprise level and at the industrial level. However, in order to conduct value chain analysis at the enterprise level, the client companies of the parent company should be classified according to whether they belong to it's value chain. The establishment of a value chain for a single company can be performed smoothly by experts, but it takes a lot of cost and time to build one which consists of multiple companies. Thus, this study proposes a model that automatically classifies the companies that form a value chain based on actual transaction data. A total of 19 transaction attribute variables were extracted from the transaction data and processed into the form of input data for machine learning method. The proposed model was constructed using the Random Forest algorithm. The experiment was conducted on a automobile parts company. The experimental results demonstrate that the proposed model can classify the client companies of the parent company automatically with 92% of accuracy, 76% of F1-score and 94% of AUC. Also, the empirical study confirm that a few transaction attributes such as transaction concentration, transaction amount and total sales per customer are the main characteristics representing the companies that form a value chain.

The Effect of New Revenue Recognition Standard on Telecom Firms' Financial Reporting : Focusing on Regulatory Accounting (새로운 수익인식기준이 통신사업자의 재무보고에 미치는 영향 : 규제회계를 중심으로)

  • Chon, Mi-Lim;Jung, Jin-Hyang;Lee, Tae-Hee
    • Journal of Digital Convergence
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    • v.17 no.11
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    • pp.163-170
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    • 2019
  • A new revenue recognition standard was adopted in 2018. The purpose of this paper is to analyse how K-IFRS 1115 'Revenue from Contracts with Customers' affects the revenue recognition of the telecommunication firms and to suggest a regulatory policy for the telecommunications industry. It shows identifying performance obligations for bundles, determining the transaction price and allocating the transaction price to the performance obligation and how to account for it using case study. The most important change in the telecommunication companies's revenue is to allocate the transaction price to two performance obligations: telecom services and mobile handset sales. As a result, sales revenue are expected to drop en masse. This study provides important implications for the regulatory accounting policy of the telecommunications industry.

IMPLEMENTATION OF STRUCTURAL DIAGRAM FOR INTELLECTUAL PROPERTY MANAGEMENT AND PROTECTION(IPMP)

  • Park, Jung-Hee;Lee, Ki-Dong;Lee, Sang-Jae
    • 한국디지털정책학회:학술대회논문집
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    • 2004.11a
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    • pp.435-448
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    • 2004
  • While Internet promises ubiquitous access, it also creates a fundamental challenge to the traditional ownership toward digital assets traded in e-commerce market. Sharing digital information freely through shared networks leads to many untapped business opportunities, but uncontrolled digital asset transaction undermines many electronic business models. Thus, in this Internet age, proper protection and safe delivery of Intellectual Property (IP) and its representation as digital assets would be a crucial ingredient of building trust in upcoming e-business environment. In this paper, we give a general structural diagram of Intellectual Property Management and Protection (IPMP) and implement an IPMP prototype based on the RSA encryption algorithm and XrML (eXtensible rights Markup Language) WORK tags to show how proper protection and safe delivery of the intellectual property is achieved. This study concludes that IPMP mechanism may contribute significantly to the volume and quality of e-commerce market.

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Thin Capitalization - The Arm's Length Approach through Blockchain

  • Lee, Jeong-Mi
    • Journal of the Korea Society of Computer and Information
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    • v.25 no.10
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    • pp.185-191
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    • 2020
  • This article proposes the unified an arm's length price of transfer pricing for thin capitalization since the scope of permanent establishment has been enlarged under Digital Economy and the implementation of Blackchain system to resolve the drawback of finding an arm's length price. The rule of current thin capitalization runs against the non-discrimination of taxation of the tax treaties and the national treatment which deals fairly with goods, sercice and capital money within the country under the treaty of commerce and navigator. In addition, the information of comparable uncontrolled debt are not available of current system to prove the debt which is not subject to the rule of thin capitalization. The united an arm's length price of transfer pricing for thin capitalization can apply to foreign investment as well as domestic corporations, thereby resolving the problem of the non-discrimination of taxation of the tax treaties and the treaty of commerce and navigation. The availability of transaction level data through Blockchain platform to decide whether the debt can be subject to thin capitalization can resolve the issue of comparable uncontrolled debt transaction which can't be found in current business transactions. This article should shed light on the proposing of the unified an arm's length price of transfer pricing for thin capitalization and Blockchain system to prevent the income shifting. This propose provide implication for policymakers on current system of thin capitalization and arm's length principles.

A Study on the Horizontal and Vertical Equity of Officially Assessed Land Price in Seoul (공시지가의 형평성에 관한 연구 - 서울특별시를 중심으로 -)

  • Jin, Dong-Suk;Choi, Yun-Soo;Kim, Jae-Myeong;Yoon, Ha-su
    • Journal of Cadastre & Land InformatiX
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    • v.50 no.2
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    • pp.133-153
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    • 2020
  • Officially assessed land price has been the index of South Korea since 1989 throughout different sectors of tax and welfare. Officially assessed land price is used as a tax valuation for the tax on property holdings, and the equity of such is the most important factor in the fair taxation for the people of South Korea. On this wise, this research analyzed and verified the horizontal and vertical inequity of officially assessed land price in Seoul by using the real transaction data between 2016 and 2018. In fact, Seoul's assessment ratio for the entire three-year period was 60.64% and it showed to increase each year. Horizontal equity was found to be most favorable in 2017, and the horizontal equity of each borough of Seoul appeared to improve each year. Vertical inequity was found to have reverse inequality in most boroughs of Seoul, however, some parts of Gangnam districts such as Gangnam-gu, Seocho-gu, and Gangdong-gu presented progressive inequality. Such example showed the need for improvement in terms of balance by each borough. The use of quantile regression demonstrated reverse inequality in most quantile, but, the differences in the value of the coefficient by each quantile showed the need for improvement of officially assessed land price with the equity of each quantile. Through the equity verification of officially assessed land price, it was analyzed that the lack of equity was found by year, by borough, and by use district. In order to redeem the lack of equity, the government must systematically supplement the real-estate disclosure system by initiating ratio studies to verify horizontal and vertical equity.

A Study on the Scheme to Revitalize the Escrow through the Stabilization of Real Estate Transactions (부동산거래 안정을 위한 에스크로우 활성화 방안에 대한 연구)

  • Kwon, Young-Sik;Park, Chang-Soo
    • The Journal of the Korea institute of electronic communication sciences
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    • v.7 no.2
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    • pp.349-356
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    • 2012
  • Entering the era of globalization, international real estate companies to advance into the country are increasing. And real estate transactions, the need for transparency and reliability are becoming even more. The alternative that real estate transactions in advance to avoid an accident is just an escrow system. Analysing the status and actual conditions of escrow in the country's real estate market and presenting the activation plans are as follows. First, the government should support building bulk service for real estate transactions. Second, tax benefits should be developed.

The Impact of Energy Crisis and Political Instability on Outsourcing: An Analysis of the Textile Industry of Pakistan

  • ARSLAN, Aniqa;QAYYUM, Arslan;AYUBI, Sharique;KHAN, Sohail Ahmed;ASAD ULLAH, Muhammad
    • The Journal of Asian Finance, Economics and Business
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    • v.9 no.3
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    • pp.235-243
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    • 2022
  • To help the industry, outsourcing was found to be the most efficient method. An extensive literature analysis was done to assess the macroeconomic factors associated with outsourcing to supplement the anxious parties' decision-making process with evidence-based comprehensive tools. As a theoretical framework for evaluating these issues, transaction cost economies and resource-based perspective theories are investigated. Outsourcing is proven to be a result of energy crises and political instability. The advantages of outsourcing assist major industries in the economy. To discover the key drivers behind outsourcing, we used the vector autoregressive (VAR model) and step-wise regression techniques for the period 1992 to 2016. This research adds to the literature in that it not only explains the energy issue but also discusses the dilemma of political instability in the country in the context of outsourcing. The findings indicate that labor cost and export tendency have a positive impact on outsourcing strategy, which confirms the study's third and fourth hypotheses. Customs tax, inflation, and the unemployment rate, on the other hand, have a negative impact on textile outsourcing in Pakistan, according to the study's fifth, sixth, and seventh hypotheses.

Comparison of the Practical Use Condition of e-finance Portal Site between Korea and U.S.A. (한.미간 e-finance 금융포털사이트의 활용실태 비교)

  • Kim Dong-Gyoon;Cha Soon-Kwean
    • Management & Information Systems Review
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    • v.7
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    • pp.21-51
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    • 2001
  • For increasing the competitiveness and efficiency of Korea's finance industry under the new e-finance paradigm, this paper compared the practical use of finance portal site' on service parts and stage between Korea and U.S.A.. The services which can be served from site are banking, mortgage and credit loan, stock, card, retirement tax, PFM(Personal Finance Management), EBPP(Electronic Bill Presentment and Payment) and Account Aggregation and so on. The stage of site can be divided as the information provide stage which only gives information about service parts, on-line transaction stage which real-time transaction is possibile and PFM services provide stage according to development process. As a result, the beginning of finance portal service in Korea was lated about 10years and more than it of U.S.A. So the development stage of domestic portal site is still staying in the first step and the providing services and contents or business model development parts are also in the same stage than U.S.A. Resides, Korea's sites mainly focus on their first service parts even though they recently aim internet finance portal, and provide not real time transaction but finance information. On the other hand, the U.S.A. site support substantially not only various on-line transactions but also distinctive personal services like PFM(Personal Finance Management), EBPP(Electronic Bill Presentment and Payment), Account Aggregation and Trans-account, brokerage, education center, mortgage loan, mutual fund, option, pension fund and IPOs and so on. Thus, the site of Korea need to establish real type of internet finance portal which provides one-stop services on every type of finance to customers in the real time and also require the strategic integration among finance institutions. The next turn, they need to build information system and education center to give best satisfaction to customers and acquire customer information and marker environment changes and need to provide distinctive services to quality customers throughout database from this. Also the site should provide various type of banking services which refereed above like PEM, EBPP and education center etc, and the government of Korea should support the building of IT infrastructure to Physical, legal, systematic, sociocultural, technical and human resource sections. This paper provided the future movement direction of the domestic finance portal through comparison and analysis on the practical use of it between Korea and U.S.A. and also wanted to contribute for developing and reading of Korea finance portal in the new era of the finance paradigm.

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