• Korean small business review
• /
• v.31 no.2
• /
• pp.85-102
• /
• 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 Intelligence and Information Systems
• /
• v.18 no.3
• /
• pp.153-169
• /
• 2012

Exhibitions have played a key role of effective marketing activity which directly informs services and products to current and potential customers. Through participating in exhibitions, exhibitors have got the opportunity to make face-to-face contact so that they can secure the market share and improve their corporate images. According to this economic importance of exhibitions, show organizers try to adopt a new IT technology for improving their performance, and researchers have also studied services which can improve the satisfaction of visitors through analyzing visit patterns of visitors. Especially, as smart technologies make them monitor activities of visitors in real-time, they have considered booth recommender systems which infer preference of visitors and recommender proper service to them like on-line environment. However, while there are many studies which can improve their performance in the side of new technological development, they have not considered the choice factor of visitors for booth recommender systems. That is, studies for factors which can influence the development direction and effective diffusion of these systems are insufficient. Most of prior studies for the acceptance of new technologies and the continuous intention of use have adopted Technology Acceptance Model (TAM) and Extended Technology Acceptance Model (ETAM). Booth recommender systems may not be new technology because they are similar with commercial recommender systems such as book recommender systems, in the smart exhibition environment, they can be considered new technology. However, for considering the smart exhibition environment beyond TAM, measurements for the intention of reuse should focus on how booth recommender systems can provide correct information to visitors. In this study, through literature reviews, we draw factors which can influence the satisfaction and reuse intention of visitors for booth recommender systems, and design a model to forecast adaptation of visitors for booth recommendation in the exhibition environment. For these purposes, we conduct a survey for visitors who attended DMC Culture Open in November 2011 and experienced booth recommender systems using own smart phone, and examine hypothesis by regression analysis. As a result, factors which can influence the satisfaction of visitors for booth recommender systems are the effectiveness, perceived ease of use, argument quality, serendipity, and so on. Moreover, the satisfaction for booth recommender systems has a positive relationship with the development of reuse intention. For these results, we have some insights for booth recommender systems in the smart exhibition environment. First, this study gives shape to important factors which are considered when they establish strategies which induce visitors to consistently use booth recommender systems. Recently, although show organizers try to improve their performances using new IT technologies, their visitors have not felt the satisfaction from these efforts. At this point, this study can help them to provide services which can improve the satisfaction of visitors and make them last relationship with visitors. On the other hands, this study suggests that they managers along the using time of booth recommender systems. For example, in the early stage of the adoption, they should focus on the argument quality, perceived ease of use, and serendipity, so that improve the acceptance of booth recommender systems. After these stages, they should bridge the differences between expectation and perception for booth recommender systems, and lead continuous uses of visitors. However, this study has some limitations. We only use four factors which can influence the satisfaction of visitors. Therefore, we should development our model to consider important additional factors. And the exhibition in our experiments has small number of booths so that visitors may not need to booth recommender systems. In the future study, we will conduct experiments in the exhibition environment which has a larger scale.

• Journal of Global Scholars of Marketing Science
• /
• v.20 no.1
• /
• pp.89-97
• /
• 2010

This study researches the effects of common features on a no-choice option with respect to regulatory focus theory. The primary interest is in three factors and their interrelationship: common features, no-choice option, and regulatory focus. Prior studies have compiled vast body of research in these areas. First, the "common features effect" has been observed bymany noted marketing researchers. Tversky (1972) proposed the seminal theory, the EBA model: elimination by aspect. According to this theory, consumers are prone to focus only on unique features during comparison processing, thereby dismissing any common features as redundant information. Recently, however, more provocative ideas have attacked the EBA model by asserting that common features really do affect consumer judgment. Chernev (1997) first reported that adding common features mitigates the choice gap because of the increasing perception of similarity among alternatives. Later, however, Chernev (2001) published a critically developed study against his prior perspective with the proposition that common features may be a cognitive load to consumers, and thus consumers are possible that they are prone to prefer the heuristic processing to the systematic processing. This tends to bring one question to the forefront: Do "common features" affect consumer choice? If so, what are the concrete effects? This study tries to answer the question with respect to the "no-choice" option and regulatory focus. Second, some researchers hold that the no-choice option is another best alternative of consumers, who are likely to avoid having to choose in the context of knotty trade-off settings or mental conflicts. Hope for the future also may increase the no-choice option in the context of optimism or the expectancy of a more satisfactory alternative appearing later. Other issues reported in this domain are time pressure, consumer confidence, and alternative numbers (Dhar and Nowlis 1999; Lin and Wu 2005; Zakay and Tsal 1993). This study casts the no-choice option in yet another perspective: the interactive effects between common features and regulatory focus. Third, "regulatory focus theory" is a very popular theme in recent marketing research. It suggests that consumers have two focal goals facing each other: promotion vs. prevention. A promotion focus deals with the concepts of hope, inspiration, achievement, or gain, whereas prevention focus involves duty, responsibility, safety, or loss-aversion. Thus, while consumers with a promotion focus tend to take risks for gain, the same does not hold true for a prevention focus. Regulatory focus theory predicts consumers' emotions, creativity, attitudes, memory, performance, and judgment, as documented in a vast field of marketing and psychology articles. The perspective of the current study in exploring consumer choice and common features is a somewhat creative viewpoint in the area of regulatory focus. These reviews inspire this study of the interaction possibility between regulatory focus and common features with a no-choice option. Specifically, adding common features rather than omitting them may increase the no-choice option ratio in the choice setting only to prevention-focused consumers, but vice versa to promotion-focused consumers. The reasoning is that when prevention-focused consumers come in contact with common features, they may perceive higher similarity among the alternatives. This conflict among similar options would increase the no-choice ratio. Promotion-focused consumers, however, are possible that they perceive common features as a cue of confirmation bias. And thus their confirmation processing would make their prior preference more robust, then the no-choice ratio may shrink. This logic is verified in two experiments. The first is a $2{\times}2$ between-subject design (whether common features or not X regulatory focus) using a digital cameras as the relevant stimulus-a product very familiar to young subjects. Specifically, the regulatory focus variable is median split through a measure of eleven items. Common features included zoom, weight, memory, and battery, whereas the other two attributes (pixel and price) were unique features. Results supported our hypothesis that adding common features enhanced the no-choice ratio only to prevention-focus consumers, not to those with a promotion focus. These results confirm our hypothesis - the interactive effects between a regulatory focus and the common features. Prior research had suggested that including common features had a effect on consumer choice, but this study shows that common features affect choice by consumer segmentation. The second experiment was used to replicate the results of the first experiment. This experimental study is equal to the prior except only two - priming manipulation and another stimulus. For the promotion focus condition, subjects had to write an essay using words such as profit, inspiration, pleasure, achievement, development, hedonic, change, pursuit, etc. For prevention, however, they had to use the words persistence, safety, protection, aversion, loss, responsibility, stability etc. The room for rent had common features (sunshine, facility, ventilation) and unique features (distance time and building state). These attributes implied various levels and valence for replication of the prior experiment. Our hypothesis was supported repeatedly in the results, and the interaction effects were significant between regulatory focus and common features. Thus, these studies showed the dual effects of common features on consumer choice for a no-choice option. Adding common features may enhance or mitigate no-choice, contradictory as it may sound. Under a prevention focus, adding common features is likely to enhance the no-choice ratio because of increasing mental conflict; under the promotion focus, it is prone to shrink the ratio perhaps because of a "confirmation bias." The research has practical and theoretical implications for marketers, who may need to consider common features carefully in a practical display context according to consumer segmentation (i.e., promotion vs. prevention focus.) Theoretically, the results suggest some meaningful moderator variable between common features and no-choice in that the effect on no-choice option is partly dependent on a regulatory focus. This variable corresponds not only to a chronic perspective but also a situational perspective in our hypothesis domain. Finally, in light of some shortcomings in the research, such as overlooked attribute importance, low ratio of no-choice, or the external validity issue, we hope it influences future studies to explore the little-known world of the "no-choice option."

• Journal of Distribution Research
• /
• v.17 no.2
• /
• pp.29-62
• /
• 2012

As distribution environment is changing rapidly and competition is more intensive in the channel of distribution, the importance of retailer image and retailer equity is increasing as a different competitive advantages. Also, consumers are not functionally oriented and that their behavior is significantly affected by the symbols such as retailer image which identify retailer in the market place. That is, consumers do not choose products or retailers for their material utilities but consume the symbolic meaning of those products or retailers as expressed in their self images. The concept of self-image congruence has been utilized by marketers and researchers as an aid in better understanding how consumers identify themselves with the brands they buy and the retailer they patronize. Although self-image congruity theory has been tested across many product categories, the theory has not been tested extensively in the retailing. Therefore, this study attempts to investigate the impact of self image congruence between retailer image and self image of consumer on retailer equity such as retailer awareness, retailer association, perceived retailer quality, and retailer loyalty. The purpose of this study is to find out whether retailer-self image congruence can be a new antecedent of retailer equity. In addition, this study tries to examine how four-dimensional retailer equity constructs (retailer awareness, retailer association, perceived retailer quality, and retailer loyalty) affect customers' repatronage intention. For this study, data were gathered by survey and analyzed by structural equation modeling. The sample size in the present study was 254. The reliability of the all seven dimensions was estimated with Cronbach's alpha, composite reliability values and average variance extracted values. We determined whether the measurement model supports the convergent validity and discriminant validity by Exploratory factor analysis and Confirmatory Factor Analysis. For each pair of constructs, the square root of the average variance extracted values exceeded their correlations, thus supporting the discriminant validity of the constructs. Hypotheses were tested using the AMOS 18.0. As expected, the image congruence hypotheses were supported. The greater the degree of congruence between retailer image and self-image, the more favorable were consumers' retailer evaluations. The all two retailer-self image congruence (actual self-image congruence and ideal self-image congruence) affected customer based retailer equity. This result means that retailer-self image congruence is important cue for customers to estimate retailer equity. In other words, consumers are often more likely to prefer products and retail stores that have images similar to their own self-image. Especially, it appeared that effect for the ideal self-image congruence was consistently larger than the actual self-image congruence on the retailer equity. The results mean that consumers prefer or search for stores that have images compatible with consumer's perception of ideal-self. In addition, this study revealed that customers' estimations toward customer based retailer equity affected the repatronage intention. The results showed that all four dimensions (retailer awareness, retailer association, perceived retailer quality, and retailer loyalty) had positive effect on the repatronage intention. That is, management and investment to improve image congruence between retailer and consumers' self make customers' positive evaluation of retailer equity, and then the positive customer based retailer equity can enhance the repatonage intention. And to conclude, retailer's image management is an important part of successful retailer performance management, and the retailer-self image congruence is an important antecedent of retailer equity. Therefore, it is more important to develop and improve retailer's image similar to consumers' image. Given the pressure to provide increased image congruence, it is not surprising that retailers have made significant investments in enhancing the fit between retailer image and self image of consumer. The enhancing such self-image congruence may allow marketers to target customers who may be influenced by image appeals in advertising.

• Asia Marketing Journal
• /
• v.14 no.2
• /
• pp.177-207
• /
• 2012

Today's consumers perceive consumption as a representation of themselves. It is not simply an act that fulfills a consumer's physical and practical needs. Even in terms of life quality, consumers increasingly want to achieve an emotional and sensible experience through consumption. Consumers now make decisions based on their need to express their position in relation to other people, pursue emotional satisfaction, and try to improve the quality of life. Culture-art products that meet such internal and external demands of consumers have made significant improvements in both quantity and quality, because of the social interest and policy support. The recognition of personal and social values of culture and arts has brought about interest in and need for culture-art products. Businesses have agilely embraced such change and actively implemented various marketing strategies utilizing culture and arts. For example, businesses began to sponsor artists who produce culture-art products while building facilities for cultural and art performances or exhibitions. Businesses have also provided performances and exhibitions free-of-charge or at affordable prices. As a result, the supply in the market has started to exceed its demand as is often the case in many of other markets. However, such imbalance has occurred not because of over-supply but because of a lack of demand. Given these circumstances, the government and culture and art related organizations, which had mainly concentrated on the supply side, started to recognize the importance of creating personal and social values in culture and arts. As a result, the government and various organizations are now creating various strategies that include policy measures to achieve their new found goal. Unfortunately however, such efforts are not meeting the expectations. Focusing on above-mentioned circumstances and problems, this study aims to find measures to create demand for culture-art products in the internal conditions of those who consume culture-art products. In other words, given that the demand for culture-art products has not increased despite all external conditions to encourage consumption, this study aims to find the reasons in consumers' value judgment on culture-art products. Though there were recent studies on culture-art products that applied consumer behavior on marketing theories, most of them focused on peripheral aspects such as people's motivation for or satisfaction from watching culture-art events. Hence, there is a need to understand what kind of value consumers perceive from culture-art products and how such value cognition leads to consumption in a comprehensive manner. This study acts as follow-up to a separate study entitled "Qualitative Study about Value Cognition and Benefits of Consumer on Culture-Art Products". The current study aims to extend practical implications that enhance the effectiveness of marketing strategies among the producing and policy agencies in the industry. The purpose of this study is to investigate dimensions of value cognition, benefits and attributes of culture-art products, and identify the effects of consumer value cognition on benefits and attributes. The questionnaire was developed based on the conceptual structure of qualitative research and previous researches. It was composed of value cognition, benefits, attributes of culture-art products and demographic variables. This survey was conducted on-line and off-line among a total of 662 persons ranging from their teens to their 50's who were living in Seoul, Gyeonggi-do, various metropolitan cities, and small and medium-sized cities. The data collected was analyzed by factor analysis and path analysis using SPSS WIN 18.0 and AMOS 16.0. This empirical study found that the dimensions of value cognition of culture-art products were categorized into personal goods, aesthetic goods and public property. This shows that the consumers perceive culture-art products as products that are worthy enough to pay the costs not just for personal benefits but also for their social values. Also the formation of value cognition for culture-art products requires special conditions unlike that for physical consumer goods and services, which simply require marketing stimuli. The dimensions of benefits pursued by consuming culture-art products were found to be composed of four types - pursuit of aesthetic benefits, pursuit of actual benefits, pursuit of emotional benefits, and pursuit of conspicuous character. This result implies that people consume culture-art products not just to pursue pleasure from emotional and intelligent satisfaction as well as social relations, but also to seek the needs and benefits embodied at a social level. The dimensions of attributes of culture-art products had seven different factors, - environmental, price, evaluation, people, artwork, composition, and personal relations - which is plentiful. This is because the attributes of culture-art products are very complicated compared to other consumer goods or services. Since culture-art products include not just cultural or artistic works but also all physical, human, environmental, and systemic elements of the products in a comprehensive manner, consumers perceive everything they experience in the process of consuming culture-art products as part of the products. The dimensions of value cognition was found to affect attributes of the products, mostly using pursued benefits as a mediating factors. This result is consistent with the result of qualitative research, and proves that applying the means-end chain theory in the reverse direction is reasonable. The result can be interpreted that consumers' value cognitions for culture-art products turns into actual benefits leading to consumers' decisions. Furthermore, this result reveals that when consumers choose culture-art products, they take into account the attributes of culture-art products depending on the benefits they pursue. These results confirm that despite their conceptual and abstract attributes, culture-art products have values that contribute to actual benefits for individual consumers and society. Hence, value cognition generates benefits to be pursued and this in turn affects the consumers' choices of attributes on products. Based on the conceptual structure of consumers' value cognitions on culture-art products and its dimensions, it is possible to find detailed methods to provide opportunities for education and training to form and reinforce positive value cognition on culture-art products. And through those methods, it will be possible to develop attributes of culture-art products according to the dimensions of pursued benefits, and allow conceptual products become the subject to valuable consumption in real life. These results provide theoretical understanding of consumer behavior in culture marketing and useful information to culture-art producers, companies that use culture and art, and government agencies that use culture-art as a mean to improve the public perception of quality of life. As a follow up on this study, there should be experimental studies that can develop criteria visualizing the demands of consumers who purchase culture-art products and identify their detailed attributes. Studies that compare characteristics of different areas within the culture-art product category and in-depth studies on a specific area or genre will also be needed. In order to develop marketing strategies for culture-art products, studies on the formation and reinforcement of positive value cognition on culture-art products and education for the development of consumer demand as well as on the development and differentiation of attributes of culture-art products depending on types of consumer groups should also follow.