• 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.

• KOREAN JOURNAL OF CROP SCIENCE
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• v.14
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• pp.1-40
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• 1973

There is a general tendency to increase nitrogen level in rice production to insure an increased yield. On the other hand, percentage of ripened grains is getting decreased with such an increased fertilizer level. Decreasing of the percentage is one of the important yield limiting factors. Especially the newly developed rice variety, 'Tongil' is characterized by a relatively low percentage of ripened grains as compared with the other leading varieties. Therefore, these studies were aimed to finding out of some measures for the improvement of ripening in rice. The studies had been carried out in the field and in the phytotron during the period of three years from 1970 to 1972 at the Crop Experiment Station in Suwon. The results obtained from the experiments could be summarized as follows: 1. The spikelet of Tongil was longer in length, more narrow in width, thinner in thickness, smaller in the volume of grains and lighter in grain weight than those of Jinheung. The specific gravity of grain was closely correlated with grain weight and the relationship with thickness, width and length was getting smaller in Jinheung. On the other hand, Tongil showed a different pattern from Jinheung. The relationship of the specific gravity with grain weight was the greatest and followed by that with the width, thickness and length, in order. 2. The distribution of grain weight selected by specific gravity was different from one variety to another. Most of grains of Jinheung were distributed over the specific gravity of 1.12 with its peak at 1.18, but many of grains of Tongil were distributed below 1.12 with its peak at 1.16. The brown/rough rice ratio was sharply declined below the specific gravity of 1.06 in Jinheung, but that of Tongil was not declined from the 1.20 to the 0.96. Accordingly, it seemed to be unfair to make the specific gravity criterion for ripened grains at 1.06 in the Tongil variety. 3. The increasing tendency of grain weight after flowering was different depending on varieties. Generally speaking, rice varieties originated from cold area showed a slow grain weight increase while Tongil was rapid except at lower temperature in late ripening stage. 4. In the late-tillered culms or weak culms, the number of spikelets was small and the percentage of ripened grains was low. Tongil produced more late-tillered culms and had a longer flowering duration especially at lower temperature, resulting in a lower percentage of ripened grains. 5. The leaf blade of Tongil was short, broad and errect, having light receiving status for photosynthesis was better. The photosynthetic activity of Tongil per unit leaf area was higher than that of Jinheung at higher temperature, but lower at lower temperature. 6. Tongil was highly resistant to lodging because of short culm length, and thick lower-internodes. Before flowering, Tongil had a relatively higher amount of sugars, phosphate, silicate, calcium, manganese and magnesium. 7. The number of spikelets of Tongil was much more than that of Jinheung. The negative correlation was observed between the number of spikelets and percentage of ripened grains in Jinheung, but no correlation was found in Tongil grown at higher temperature. Therefore, grain yield was increased with increased number of spikelets in Tongil. Anthesis was not occurred below 21$^{\circ}C$ in Tongil, so sterile spikelets were increased at lower temperature during flowering stage. 8. The root distribution of Jinheung was deeper than that of Tongil. The root activity of Tongil evaluated by $\alpha$-naphthylamine oxidation method, was higher than that of Jinheung at higher temperature, but lower at lower temperature. It is seemed to be related with discoloration of leaf blades. 9. Tongil had a better light receiving status for photosynthesis and a better productive structure with balance between photosynthesis and respiration, so it is seemed that tongil has more ideal plant type for getting of a higher grain yield as compared with Jinheung. 10. Solar radiation during the 10 days before to 30 days after flowering seemed enough for ripening in suwon, but the air temperature dropped down below 22$^{\circ}C$ beyond August 25. Therefore, it was believed that air temperature is one of ripening limiting factors in this case. 11. The optimum temperature for ripening in Jinheung was relatively lower than that of Tongil requriing more than $25^{\circ}C$. Air temperature below 21$^{\circ}C$ was one of limiting factors for ripening in Tongil. 12. It seemed that Jinheung has relatively high photosensitivity and moderate thermosensitivity, while Tongil has a low photosensitivity, high thermosensitivity and longer basic vegetative phase. 13. Under a condition of higher nitrogen application at late growing stage, the grain yield of Jinheung was increased with improvement of percentage of ripened grains, while grain yield of Tongil decreased due to decreasing the number of spikelets although photosynthetic activity after flowering was. increased. 14. The grain yield of Jinheung was decreased slightly in the late transplanting culture since its photosynthetic activity was relatively high at lower temperature, but that of Tonil was decreased due to its inactive photosynthetic activity at lower temperature. The highest yield of Tongil was obtained in the early transplanting culture. 15. Tongil was adapted to a higher fertilizer and dense transplanting, and the percentage of ripened grains was improved by shortening of the flowering duration with increased number of seedlings per hill. 16. The percentage of vigorous tillers was increased with a denser transplanting and increasing in number of seedlings per hill. 17. The possibility to improve percentage of ripened grains was shown with phosphate application at lower temperature. The above mentioned results are again summarized below. The Japonica type leading varieties should be flowered before August 20 to insure a satisfactory ripening of grains. Nitrogen applied should not be more than 7.5kg/10a as the basal-dressing and the remained nitrogen should be applied at the later growing stage to increase their photosynthetic activity. The morphological and physiological characteristics of Tongil, a semi-dwarf, Indica $\times$ Japonica hybrid variety, are very different from those of other leading rice varieties, requring changes in seed selection by specific gravity method, in milling and in the cultural practices. Considering the peculiar distribution of grains selected by the method and the brown/rough rice ratio, the specific gravity criterion for seed selection should be changed from the currently employed 1.06 to about 0.96 for Tongil. In milling process, it would be advisable to bear in mind the specific traits of Tongil grain appearance. Tongil is a variety with many weak tillers and under lower temperature condition flowering is delayed. Such characteristics result in inactivation of roots and leaf blades which affects substantially lowering of the percentage of ripened grains due to increased unfertilized spikelets. In addition, Tongil is adapted well to higher nitrogen application. Therefore, it would be recommended to transplant Tongil variety earlier in season under the condition of higer nitrogen, phosphate and silicate. A dense planting-space with three vigorous seedlings per hill should be practiced in this case. In order to manifest fully the capability of Tongil, several aspects such as the varietal improvement, culural practices and milling process should be more intensively considered in the future.he future.

• Korean Journal of Agricultural Science
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• v.4 no.2
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• pp.344-390
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• 1977

The purpose of this paper was to schedule optimum cutting strategy which could maximize the total yield under certain restrictions on periodic timber removals and harvest areas from an industrial forest, based on a linear programming technique. Sensitivity of the regulation model to variations in restrictions has also been analyzed to get information on the changes of total yield in the planning period. The regulation procedure has been made on the experimental forest of the Agricultural College of Seoul National University. The forest is composed of 219 cutting units, and characterized by younger age group which is very common in Korea. The planning period is devided into 10 cutting periods of five years each, and cutting is permissible only on the stands of age groups 5-9. It is also assumed in the study that the subsequent forests are established immediately after cutting existing forests, non-stocked forest lands are planted in first cutting period, and established forests are fully stocked until next harvest. All feasible cutting regimes have been defined to each unit depending on their age groups. Total yield (Vi, k) of each regime expected in the planning period has been projected using stand yield tables and forest inventory data, and the regime which gives highest Vi, k has been selected as a optimum cutting regime. After calculating periodic yields and cutting areas, and total yield from the optimum regimes selected without any restrictions, the upper and lower limits of periodic yields(Vj-max, Vj-min) and those of periodic cutting areas (Aj-max, Aj-min) have been decided. The optimum regimes under such restrictions have been selected by linear programming. The results of the study may be summarized as follows:- 1. The fluctuations of periodic harvest yields and areas under cutting regimes selected without restrictions were very great, because of irregular composition of age classes and growing stocks of existing stands. About 68.8 percent of total yield is expected in period 10, while none of yield in periods 6 and 7. 2. After inspection of the above solution, restricted optimum cutting regimes were obtained under the restrictions of Amin=150 ha, Amax=400ha, $Vmin=5,000m^3$ and $Vmax=50,000m^3$, using LP regulation model. As a result, about $50,000m^3$ of stable harvest yield per period and a relatively balanced age group distribution is expected from period 5. In this case, the loss in total yield was about 29 percent of that of unrestricted regimes. 3. Thinning schedule could be easily treated by the model presented in the study, and the thinnings made it possible to select optimum regimes which might be effective for smoothing the wood flows, not to speak of increasing total yield in the planning period. 4. It was known that the stronger the restrictions becomes in the optimum solution the earlier the period comes in which balanced harvest yields and age group distribution can be formed. There was also a tendency in this particular case that the periodic yields were strongly affected by constraints, and the fluctuations of harvest areas depended upon the amount of periodic yields. 5. Because the total yield was decreased at the increasing rate with imposing stronger restrictions, the Joss would be very great where strict sustained yield and normal age group distribution are required in the earlier periods. 6. Total yield under the same restrictions in a period was increased by lowering the felling age and extending the range of cutting age groups. Therefore, it seemed to be advantageous for producing maximum timber yield to adopt wider range of cutting age groups with the lower limit at which the smallest utilization size of timber could be produced. 7. The LP regulation model presented in the study seemed to be useful in the Korean situation from the following point of view: (1) The model can provide forest managers with the solution of where, when, and how much to cut in order to best fulfill the owners objective. (2) Planning is visualized as a continuous process where new strateges are automatically evolved as changes in the forest environment are recognized. (3) The cost (measured as decrease in total yield) of imposing restrictions can be easily evaluated. (4) Thinning schedule can be treated without difficulty. (5) The model can be applied to irregular forests. (6) Traditional regulation methods can be rainforced by the model.

• KOREAN JOURNAL OF CROP SCIENCE
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• v.8 no.1
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• pp.129-177
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• 1970

For the purpose of establishing the systematized technical scheme of the cooperative rice cultivation which has most significant impact to improve rice productivity and the farm management, the author have studied the cultivation practices, and the variation of rice growth and yield between the cooperative rice cultivation and the individual rice cultivation at random selected 18 paddy fields. The author also have investigated through comparative method on the cultivation practices, management, organization and operation scheme of the two different rice cultivation methods at 460 paddy fields. The economic feasibility has been ana lysed and added in this report. The results obtained from this study are summarized as follows; 1. In the nursery, the average amount of fertilizer application, especially, phosphate and potassium, and the frequency of chemicals spray for the disease, insect and pest control at the cooperative rice cultivation are significantly higher than those of the individual rice cultivation. 2. The cultivation techniques of the cooperative rice farming after the transplanting can be characterized by a) the earlier transplanting of rice, b) the denser hills per unit area and the lesser number of seedlings per hill, c) the application of larger quantities of fertilizer including nitrogen, phosphate and potassium, d) more divided application of fertilizers, split doses of the nitrogen and potassium, e) the increased frequencies of the chemicals spray for the prevention of disease, insect and pest damages. 3. The rate of lodging in the cooperative rice cultivation was slightly higher than that of the individual rice cultivation, however, the losses of rice yield owing to the occurrence of rice stem borer and grass leaf roller in the cooperative rice cultivation were lower than that of the individual rice cultivation. 4. The culm length, panicle length, straw weight and grain-straw ratio are respectively higher at the cooperative rice cultivation, moreover, the higher variation of the above factors due to different localities of the paddy fields found at the individual rice cultivation. 5. The number of panicles, number of flowers per panicle and the weight of 1, 000 grains, those contributing components to the rice yield were significantly greater in the cooperative rice cultivation, however, not clear difference in the maturing rate was observed. The variation coefficient of the yield component in the cooperative cultivation showed lower than that or the individual rice cultivation. 6. The average yield of brown rice per 10 are in the cooperative rice cultivation obtained 459.0 kilograms while that of the individual rice cultivation brought 374.8 kilograms. The yield of brown rice in the cooperative rice cultivation increased 84.2 kilogram per 10 are over the individual rice cultivation. With lower variation coefficient of the brown rice yield in the cooperative rice cultivation, it can be said that uniformed higher yield could be obtained through the cooperative rice cultivation. 7. Highly significant positive correlations shown between the seeding date and the number of flowers per panicle, the chemical spray and the number of flowers per panicle, the transplanting date and the number of flowers per panicle, phosphate application and yield, potassium application and maturing rate, the split application of fertilizers and yield. Whilst the significant negative correlation was shown between the transplanting date and the maturing rate 8. The results of investigation from 480 paddy fields obtained through comparative method on the following items are identical in general with those obtained at 18 paddy fields: Application of fertilizers, chemical spray for the control of disease, insects and pests both in the nursery and the paddy field, transplanting date, transplanting density, split application of fertilizers and yield n the paddy fields. a) The number of rice varieties used in the cooperative rice cultivation were 13 varieties while the individual rice cultivation used 47 varieties. b) The cooperative rice cultivation has more successfully adopted improved cultivation techniques such as the practice of seed disinfection, adoption of recommended seeding amount, fall ploughing, application of red soil, introduction of power tillers, the rectangular-type transplanting, midsummer drainage and the periodical irrigation. 9. The following results were also obtained from the same investigation and they are: a) In the cooperative rice cultivation, the greater part of the important practices have been carried out through cooperative operation including seed disinfection, ploughing, application of red soil and compost, the control of disease, insects and pests, harvest, threshing and transportation of the products. b) The labor input to the nursery bed and water control in the cooperative rice cultivation was less than that of the individual rice cultivation while the higher rate of labor input was resulted in the red soil and compost application. 10. From the investigation on the organization and operation scheme of the cooperative rice cultivation, the following results were obtained: a) The size of cooperative rice cultivation farm was varied from. 3 ha to 7 ha and 5 ha farm. occupied 55.9 percent of the total farms. And a single cooperative farm was consisted of 10 to 20 plots of paddies. b) The educational back ground of the staff members involved in the cooperative rice cultivation was superior than that of the individual rice cultivation. c) All of the farmers who participated to the questionaires have responded that the cooperative rice cultivation could promise the increased rice yield mainly through the introduction of the improved method of fertilizer application and the effective control of diseases, insects and pests damages. And the majority of farmers were also in the opinion that preparation of the materials and labor input can be timely carried out and the labor requirement for the rice cultivation possibly be saved through the cooperative rice cultivation. d) The farmers who have expressed their wishes to continue and to make further development of the cooperative rice cultivation was 74.5 percent of total farmers participated to the questionaires. 11. From the analysis of economical feasibility on the two different methods of cultivation, the following results were obtained: a) The value of operation cost for the compost, chemical fertilizers, agricultural chemicals and labor input in the cooperative rice cultivation was respectively higher by 335 won, 199 won, 288 won and 303 won over the individual rice cultivation. However, the other production costs showed no distinct differences between the two cultivation methods. b) Although the total value of expenses for the fertilizers, agricultural chemicals, labor input and etc. in the cooperative rice cultivation were approximately doubled to the amount of the individual rice cultivation, the net income, substracted operation costs from the gross income, was obtained 24, 302 won in the cooperative rice cultivation and 20, 168 won was obtained from the individual rice cultivation. Thereby, it can be said that net income from the cooperative rice cultivation increased 4, 134 won over the individual rice cultivation. It was revealed in this study that the cooperative rice cultivation has not only contributed to increment of the farm income through higher yield but also showed as an effective means to introduce highly improved cultivation techniques to the farmers. It may also be concluded, therefore, the cooperative rice cultivation shall continuously renovate the rice production process of the farmers.