• Journal of the Korea Society of Computer and Information
• /
• v.25 no.10
• /
• pp.185-191
• /
• 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.

• THE INTERNATIONAL COMMERCE & LAW REVIEW
• /
• v.46
• /
• pp.351-380
• /
• 2010

Multinational Enterprises set the prices for transactions between affiliates based principally on their global interest. But the customs authority in Korea wants to set the arm's length price as high as possible to get higher dutiable value for customs purpose, while the internal tax authority in Korea prefers lower arm's length price to get higher value for corporation tax purpose by cutting costs. Problem caused by the inconsistent valuation methods on the same imported goods of the two tax authorities is the single most important tax issue facing multinational enterprises. In the meantime, the customs authority in Korea has thought that it is a universal trend worldwide for the Customs and Internal tax authorities to adopt different methods of valuation on transfer prices between related parties, so KCS couldn't accept APA prices. But the internal tax authority in Korea has taken the initiative in APA program so NTS provided taxpayer with safe-harbor. Recently, KCS created the Advance Customs Valuation Arrangement(ACVA) provisions in the 2008 revision bill of the Customs Act through benchmarking APAs program. Can APAs work for customs? Neither WCO or OECD presents any recommendation on the integration of the valuation methods, but calls for close cooperation between two authorities, which still leaves taxpayers very unstable. We will start to seek ways to integrate the customs valuation and transfer pricing in this study.

• Asia-Pacific Journal of Business
• /
• v.10 no.4
• /
• pp.197-204
• /
• 2019

The transfer pricing mechanism is a tool commonly used to transfer the tax base from countries with high taxation in countries with low taxation. In many countries, this financial operations generate significant tax revenue losses. In an attempt to limit tax revenue losses, many public authorities have introduced regulations on transfer pricing, but the effectiveness of these rules has proved limited, and they contributed to the increasing complexity of tax laws and to the appearance of additional costs for companies. Historically, transfer pricing (TP) was not a substantial issue in Mongolia. The tax legislation contains basic TP rules, but there is limited guidance and enforcement in practice. At the moment, Mongolian tax authorities are not conducting specific transfer pricing audits. Nevertheless, tax authorities are starting to pay more attention to transactions between related parties and potential transfer pricing adjustments. This study examines a transfer pricing regulations of Mongolia.

• Journal of the Korea Fashion and Costume Design Association
• /
• v.6 no.3
• /
• pp.31-43
• /
• 2004

The purpose of this study is to provide basic data on the propriety of the ready-to-made garment sizes of the boys aged between 10 and 11. The data were collected from 315 boys in the capital area. They were surveyed during the period of April, 2004. Data analysis has been performed through descriptive statistics, $x^2$-test, t-test, ANOVA and Duncan test using SPSS ver.10. The results of the analysis are as follows. According to the result of investigating the favorite fashion style of boys, most boys aged between 10 and 11 preferred casual style(jean pants & T-shirts). Boys of age 10 preferred formal style and 11-year-old boys tend to prefer hip-hop style. When boys buy garments, boys aged between 10 and 11 were influenced by their mother or family. The store in which 10-year-old boys purchased their garments was either a children's or a sports wear store, and boys of 11 age prefer young casual wear store. The highest factors of dissatisfaction on buying garments were price and size. According to the result of evaluating fitting problems, the highest degree of dissatisfaction upon proper fitness upper-arm circumference, waist circumference and pants length.

• Korean Business Review
• /
• v.11
• /
• pp.319-341
• /
• 1998

Transfer pricing is a process for determining the prices of products, technology and services among affiliated companies. Although taxation problems arising from international investment are not now, they have become more important in recent years as a consequence of the growing internationalization of economic activities. So, trans pricing to shift their income and expenses from one country to another has made it difficult for tax administrations to impose tax collectly. Our government also applies arm' length methods to decide equitable tax. In the case of intangibles, because of the characteristics of the market, it is not easy to find the comparable uncontrolled transactions and it is almost impossible to apply cost=plus method or resale price method. This paper treats these problem, examining U.S. regulations and OECD guidelines and analysing the practice of transactions and the application of other methods.

• Journal of the Korean Society of Clothing and Textiles
• /
• v.30 no.2 s.150
• /
• pp.207-220
• /
• 2006

The purpose of the study is to develop the basic pattern of casual jacket for men aged between 25 and 34. Compared to the tailored jackets, casual jackets are designed much more diverse form depending on the target customer, price range and moreover fashion trend. Therefore in order to reduce the cost and time of developing new style, pattern draft from the basic pattern is better approach rather than develop each style form the measurements every time. For men's casual jacket pattern draft, the basic pattern of fit and comfort was developed through following research procedures. 173 men were surveyed about their habit of buying and wearing of casual jackets. MDs and pattern designers of 10 casual wear brands for men were interviewed. As a starting point, 3 different basic patterns were selected. 2 patterns were from the 2 interviewed brands and the last one was the pattern of ESMOD. The 3 patterns were studied by means of comparing measurements and general styling. As a results it was found that the pattern of S brand is featuring I silhouette, the pattern of K brand is featuring H silhouette and the pattern of ESMOD is featuring Y silhouette. The results of wearing test showed that the pattern of S brand is the best among the three. They were to add ease around the chest line and waist line, to relocate the waist line and the break point, to increase the jacket length and upper arm width. The improved pattern was made of polyester for the wearing test. The wearing test showed developed pattern was improved significantly. To verify the use of developed basic pattern, two buttoned single jacket was made.

• Journal of Arbitration Studies
• /
• v.24 no.1
• /
• pp.45-58
• /
• 2014

It is a well recognised rule in international law that the property of aliens cannot be taken. The question of whether indirect expropriation and government regulatory measures require compensation is an important issue in international investment law. Bilateral investment treaties and other investment agreements contain brief and general indirect expropriation provisions. These focus on the effect of government action and do not address the distinction between compensable and non-compensable regulatory actions. It is generally accepted that a state is not responsible for loss of property or for other economic disadvantages resulting from bona fide general taxation accepted as within the police power of states, provided it is not discriminatory. Yukos Oil Company is a Russian oil and gas company engaged in exploration, refining, and marketing activities. It is one of the largest oil and gas companies in the world. Yukos Oil Company has its production operations in Russia and markets its products in Europe. An international tribunal ordered the Russian government to compensate a group of Spanish investors for the losses they suffered when Russia seized the Yukos Oil Company on July 26, 2012. This has been the subject of several judicial proceedings and academic publications. This paper explores which circumstances do not lead to taxation amounting to expropriation. The author suggests that under the following circumstances, taxation would not amount to expropriation. First, taxation should be non-discriminatory. Also a lawful exercise of the taxation powers of governments would not amount to expropriation.