• Title/Summary/Keyword: 관리적 특성

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Factors Affecting International Transfer Pricing of Multinational Enterprises in Korea (외국인투자기업의 국제이전가격 결정에 영향을 미치는 환경 및 기업요인)

  • Jun, Tae-Young;Byun, Yong-Hwan
    • 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.

The Consideration of nuclear medicine technologist's occupational dose from patient who are undergoing 18F-FDG Whole body PET/CT : Aspect of specific characteristic of patient and contact time with patient (18F-FDG Whole Body PET/CT 수검자의 거리별 선량 변화에 따른 방사선 작업종사자의 유효선량 고찰: 환자 고유특성 및 응대시간 측면)

  • Kim, Sunghwan;Ryu, Jaekwang;Ko, Hyunsoo
    • The Korean Journal of Nuclear Medicine Technology
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    • v.22 no.1
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    • pp.67-75
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    • 2018
  • Purpose The purpose of this study is to investigate and analyze the external dose rates of $^{18}F-FDG$ Whole Body PET/CT patients by distance, and to identify the main factors that contribute to the reduction of radiation dose by checking the cumulative doses of nuclear medicine technologist(NMT). Materials and Methods After completion of the $^{18}F-FDG$ Whole Body PET/CT scan($75.4{\pm}3.3min$), the external dose rates of 106 patients were measured at a distance of 0, 10, 30, 50, and 100 cm from the chest. Gender, age, BMI(Body Mass Index), fasting time, diabetes mellitus, radiopharmaceutical injection information, creatine value were collected to analyze individual factors that could affect external dose rates from a patient's perspective. From the perspective of NMT, personal pocket dosimeters were worn on the chest to record accumulated dose of NMT who performed the injection task($T_1$, $T_2$ and $T_3$) and scan task($T_4$, $T_5$ and $T_6$). In addition, patient contact time with NMT was measured and analyzed. Results External dose rates from the patient for each distance were calculated as $246.9{\pm}37.6$, $129.9{\pm}16.7$, $61.2{\pm}9.1$, $34.4{\pm}5.9$, and $13.1{\pm}2.4{\mu}Sv/hr$ respectively. On the patient's aspect, there was a significant difference in the proximity of gender, BMI, Injection dose and creatine value, but the difference decreased as the distance increased. In case of dialysis patient, external dose rates for each distance were exceptionally higher than other patients. On the NMT aspect, the doses received from patients were 0.70, 1.09, $0.55{\mu}Sv/person$ for performing the injection task($T_1$, $T_2$, and $T_3$), and were 1.25, 0.82, $1.23{\mu}Sv/person$ for performing the scan task($T_4$, $T_5$, $T_6$). Conclusion we found that maintaining proper distance with patient and reducing contact time with patient had a significant effect on accumulated doses. Considering those points, efforts such as sufficient water intake and encourage of urination, maintaining the proper distance between the NMT and the patient(at least 100 cm), and reducing the contact time should be done for reducing dose rates not only patient but also NMT.

Economics and Ground Cover Growth Characteristics of a New Method of Shallow Soil Artificial Foundation Planting (저토심 인공지반 녹화공법의 경제성 및 도입 가능한 지피식물의 생육특성)

  • Choi, Jin-Woo;Kim, Hag-Kee;Lee, Kyong-Jae;Kang, Hyun-Kyung
    • Journal of the Korean Institute of Landscape Architecture
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    • v.37 no.5
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    • pp.98-108
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    • 2009
  • The purpose of this study is to analyze the characteristics of limited methods, economics and breeding appropriateness of native and imported ground cover plants in the methodology of a shallow soil rooftop garden. The new shallow soil rooftop gardening method uses a total of 13cm in soil thickness, including 4.5cm of top soil on a 7.5cm rock-wool-mat stacked onto a 1cm roll-type-draining plate. The total construction cost for each method of soil level within the design price standard for SEDUM BLOCK is 89,433won/$m^2$, and for DAKU is 92,550won/$m^2$. By comparing those two methods, the construction cost of the shallow soil artificial foundation methodology is 45,000won/$m^2$; this shows the new method is 50% less expensive than the existing method of shallow soil rooftop gardening. The experiment was executed on the rooftop of the Korean National Housing Corporation to ensure validity of the shallow soil artificial foundation planting, and the sample plants which were imported and grown now in native covering. A list investigating the growing plants was made of the cover rate in each plant class, both while alive and the dry plant weight. The native ground cover plants, Sedum kamtschaticum, Sedum middendorffianum, Allium senescens, Sedum sarmentosum, Aquilegia buergariana, and Caryopteris incana increased the cover rate, live weight and dry weight in the shallow soil artificial foundation method. Among the imported cover plants, Sedum sprium and Sedum reflexum, the cover rate increased and growth conditions improved. However, some species needed weed maintenance. After examination with the less expensive shallow soil artificial foundation method and growth analysis, it was found that rooftop gardens are a low-cost option and the growth of plants is great. This result shows the new method can contribute to the proliferation of rooftop gardens in urban settings.

Relationship between Radiation and Yield of Sweet Pepper Cultivars (광량과 파프리카 품종에 따른 수량과의 상호관계)

  • Myung, Dong Ju;Bae, Jong Hyang;Kang, Jong Goo;Lee, Jeong Hyun
    • Journal of Bio-Environment Control
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    • v.21 no.3
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    • pp.243-246
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    • 2012
  • The study was aimed at the development of the simple linear regression model to estimate the fruit yield of sweet pepper and to support decision-making management for growing sweet pepper crop in Korea. For quantitative analysis of relationship between environmental data and periodical yield of sweet pepper the data obtained from the commercial Venlo-type glasshouse for 2 years. Obtained periodical yield data of five different cultivars and radiation data were accumulated and fitted by linear regression. A significant linear relationship was found between radiation integral and fruit yield, whereas the production per unit of radiation was different between cultivars. The slope of linear regression could indicate as light use efficiency for fruit production ($LUE_F$, $g{\cdot}MJ^{-1}$). $LUE_F$ of 'Ferrari' was $5.85g{\cdot}MJ^{-1}$, 'Fiesta' 5.32 for first year and $4.75g{\cdot}MJ^{-1}$ and for second year, 'President' was $4.66g{\cdot}MJ^{-1}$, 'Cupra' was $3.86g{\cdot}MJ^{-1}$, and 'Boogie' was $6.48g{\cdot}MJ^{-1}$. The amount of light requirement for the unit gram of fruit was between $25.88J{\cdot}g^{-1}$, for 'Cupra' and $15.42J{\cdot}g^{-1}$ for 'Boogie'. Although we found the linear relationship between radiation and fruit yield, $LUE_F$ was varied between cultivars and as well as year. The linear relationship could describe the fruit yield as function of radiation, but it needed more variable to generalization of the production, such as cultivar specifications, temperature, and number of fruits set per plant or unit of ground.

The Effect of Oral Health Behavior by Oral Health Belief of Student in Dental Hygiene Department of College Students in Seoul (서울지역 일부대학 치위생과 학생의 구강건강신념이 구강보건행태에 미치는 영향)

  • Park, Mi-Sook
    • Journal of dental hygiene science
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    • v.11 no.2
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    • pp.107-119
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    • 2011
  • The purpose of this study was to examine the effects of oral health behavior by oral health belief from the students in the dental hygienics department who take charge of oral health office, and therefore to lead a clear oral health care, to complete desirable oral health belief, and finally to utilize them for oral health field. The survey was conducted using structured self-administered questionnaires based on oral health belief model targeting 163 students in the dental hygienics department of one of the college in Seoul, and collected data were statistically analyzed using the SPSS 18.0 program. As a result of analysis to determine that the oral health belief significantly affects on the oral heal behavior, the personal variables such as age, economic status and occupation, and the seriousness for the oral health belief were indicated to be significant variables(p<0.05), and as a result of analysis that effects on the number of the oral health behavior, the susceptibility and the seriousness were indicated to be significant variables for oral health belief(P<0.05). As a conclusion, oral health belief was identified as a factor of salience through understanding that oral health belief of the students in the dental hygienics department effects on oral health behavior based on an oral health belief model, and it can be concluded that the necessity of oral health belief investigation should be discussed as a crucial issue to provide a more effective oral health promotion plan.

Soil Contamination of Heavy Metals in National Industrial Complexes, Korea (국내 주요 국가산업단지에서 중금속에 의한 토양오염)

  • Jeong, Tae-Uk;Cho, Eun-Jeong;Jeong, Jae-Eun;Ji, Hwa-Seong;Lee, Kyeong-Sim;Yoo, Pyung-Jong;Kim, Gi-Gon;Choi, Ji-Yeon;Park, Jong-Hwan;Kim, Seong-Heon;Heo, Jong-Soo;Seo, Dong-Cheol
    • Korean Journal of Environmental Agriculture
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    • v.34 no.2
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    • pp.69-76
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    • 2015
  • BACKGROUND: Contamination of soils by heavy metals is the serious environmental problem. In particular, industrial processing is one of the main sources of heavy metal contamination. The objective of this study was to investigate the distribution characteristics of heavy metals in soils collected from industrial complex. METHODS AND RESULTS: In this study, the soil contamination and enrichment factor (EF) of heavy metals were investigated in three national industrial complexes such as Yeosu, Ulsan and Sihwa Banwal industrial complexes. The target heavy metals includes Cd, Cu, As, Hg, Pb, Cr, Zn, and Ni. The results showed that the contents of Cd, Hg, Pb, Zn and Ni in Yeosu and the contents of Cu, As and Cr in Sihwa Banwal were higher than in any other industrial complex. The results of principal component analysis(PCA) in Yeosu, Ulsan and Sihwa Banwal complex could be explained up to approximately 81.4, 69.1 and 70.9% by two factor, respectively. Enrichment factors of Cd, Pb and Zn in all the investigated industrial complexes were above 1.0 that was the value judged to be a high contamination. And EF of Cr was above 1.0 in Sihwa Banwal complex. EF of Zn in all sites was generally high from the other heavy metals. CONCLUSION: Therefore, soils maybe significantly affected by heavy metals (especially, Cd, Pb and Zn) present in the emissions from industrial complexes.

Effect of Nitrogen Fertigation on The Growth and Nutrition Uptake of 'Brightwell' Rabbiteye Blueberry (질소관비 수준이 래빗아이 블루베리 '브라이트웰'의 생장과 양분흡수에 미치는 영향)

  • Kwack, Yong-Bum;Chae, Won-Byoung;Lee, Mock-hee;Jeong, Hae-Won;Rhee, Han-Cheol;Kim, Jin-Gook;Kim, Hong-Lim
    • Korean Journal of Environmental Agriculture
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    • v.36 no.3
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    • pp.161-168
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    • 2017
  • BACKGROUND: Rabbiteye blueberry(Vaccinium ashei Reade) has low nutrient uptake efficiency due to its shallow and fibrous root system without root hairs. This study was carried out to establish an efficient nutrient application standard by investigating the effect of nitrogen fertigation on the growth and fruit characteristics of rabbiteye blueberry. METHODS AND RESULTS: 'Brightwell' rabbiteye blueberry was treated with 0, 50, 100 and 200% nitrogen fertigation of recommended fertilizer application (6, 9 and 14 g/bush in the first, second and third years, respectively). The results showed that leaf nitrogen content significantly correlated with the fruit weight and fruit yield. However, canopy area, dry weight, sugar and anthocyanin contents did not correlate significantly with the leaf nitrogen content. The leaf and stem dry weights of 'Brightwell' rabbiteye blueberry during the third year of planting were the highest with 50% nitrogen fertigation (leaf dry weight=723.7 g/bush; stem dry weight=890.7 g/bush). Maximum fruit yield of 'Brightwell' rabbiteye blueberry (12.9 kg/bush) was observed during the third year of planting with 50% nitrogen fertigation and this was about 70% greater than the treatment that received no nitrogen fertigation. The fruit yields of 'Brightwell' rabbiteye blueberry during the third year of planting treated with 100 and 200% nitrogen fertigation were 11.0 and 11.5 kg/bush, and these were 17 and 12%lower than the 50% nitrogen fertigation treatment, respectively. Further, the efficiency of nitrogen utilization was the highest (90%) with 50% nitrogen fertigation and lowest (18%) with 200% nitrogen fertigation. CONCLUSION: The results of this study suggests that fertigation with 50% of the recommended fertilizer could be most effective for enhancing the growth and nitrogen use efficiency of rabbiteye blueberry.

Growth of Bioenergy Crop Miscanthus sacchariflorus cv. Geodae 1 on Barren Reclaimed Land Applied with Solidified Sewage Sludge in Landfill Sites (하수슬러지 고화물을 처리한 유휴 간척지토양에서 바이오에너지작물 거대 1호의 생육특성 연구)

  • An, Gi Hong;Jang, Yun-Hui;Um, Kyoung Ran;Yu, Gyeong-Dan;Lee, Ji-Eun;Cha, Young-Lok;Moon, Yun-Ho;Ahn, Jong Woong
    • KOREAN JOURNAL OF CROP SCIENCE
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    • v.60 no.3
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    • pp.374-380
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    • 2015
  • This study firstly provides basic data for selection of cultivatable bioenergy grass in barren reclaimed lands applied with solidified sewage sludge. The experimental plots consisted of a plot containing reclaimed land mixed with solidified sewage sludge (MSS 50), a plot covered by solidified sewage sludge (CSS 100), and an original reclaimed soil plot (ORS). The growth, biomass production of bioenergy grasses and soil chemical properties were investigated in each experimental plot for 5 years. The organic matter (OM) and total nitrogen (T-N) content in both MSS 50 and CSS 100 were considerably higher than those in ORS. In bioenergy grasses, M. sacchariflorus cv. Geodae 1 showed an excellent growth and adaptability on reclaimed land applied with solidified sewage sludge. The application of solidified sewage sludge may provided soil nutrition in the reclaimed land due to the fact that bioenergy crops grew better in soils applied with solidified sewage sludge than in untreated soils, and treated soils had higher OM and T-N content than untreated soils. This study suggests that M. sacchariflorus cv. Geodae 1 is the most suitable biomass feedstock crop for biomass production and that solidified sewage sludge may be used as a soil material for cultivation of bioenergy grass on reclaimed lands.

Perinatal Outcomes of In Vitro Fertilized Twins in Women of Advanced Age (고연령 산모에서 체외 수정 시술로 태어난 쌍생아의 임상 양상)

  • Chung, In-Hyuk;Kim, Sung-Woo;Jo, Heui-Seung;Lee, Kyu-Hyung
    • Neonatal Medicine
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    • v.18 no.2
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    • pp.197-203
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    • 2011
  • Purpose: The purpose of this study is to compare perinatal outcomes between in vitro fertilization (IVF) twins and naturally conceived twins born to women aged 35 years or older and to provide basic information for taking care of IVF twins born to women aged 35 years or older. Methods: We reviewed the records of perinatal and neonatal outcomes in 288 IVF twins and 220 naturally conceived twins born to women aged 35 years or older between January 2001 and December 2010 at CHA Bundang Medical Center. Results: No difference was observed in the maternal ages of mothers giving birth to IVF twins and those giving birth to naturally conceived twins. Gestational ages and birth weights of IVF twins were not different from those of naturally conceived twins. Various perinatal outcomes, including gestational diabetes mellitus, pregnancy-induced hypertension, placenta previa, premature amniotic membrane rupture, and need for a Cesarean section did not differ between the 2 groups. However, the 1-min and 5-min Apgar scores (P=0.019 and P=0.045, respectively) were different between the 2 groups. The incidence of early-onset sepsis was lower in the IVF twins than in the naturally conceived twins (P=0.02). However, the 2 groups did not show any difference in the incidence of respiratory distress syndrome, bronchopulmonary dysplasia, patent ductus arteriosus, necrotizing enterocolitis, intraventricular hemorrhage, and other congenital anomalies. Conclusion: The perinatal outcomes in IVF twins born to women aged 35 years or older were not significantly different from those of naturally conceived twins.

Biological Water Quality Assessments in Wastewater-impacted and Non-impacted Streams (폐수처리 시설의 영향에 따른 영산강 수계의 생물학적 수질 평가)

  • An, Kwang-Guk;Kim, Kang-Il;Kim, Ja-Hyun
    • Korean Journal of Ecology and Environment
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    • v.40 no.1
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    • pp.82-92
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    • 2007
  • In 2003, we evaluated biological water quality at twelve sites of Youngsan River using community analysis, fish compositions, and the Index of Biological Integrity (IBI). Of the twelve, four sites were the controls, which have no point sources in the upstream and the remaining eight sites were the impacted sites, which are influenced by wastewater treatment plant (WTP) and agro-industrial complex. Model values of the IBI, based on 12 sites data, averaged 28 (n=12, range: $18{\sim}44$), indicating fair poor condition according to the criteria of US EP A (1993). In the mean time, mean IBI in the control sites (S3, S5, S6, S11) was 42 (n=4, range: $38{\sim}44$), indicating a good condition, whereas mean IBI in the impacted sites was 21, indicating a poor condition. Mean IBI value in the control, thus, was greater by 2 fold than that in the WTP sites. The spatial pattern of IBI values was similar to the patterns of species diversity index and species richness index, except for Site 11, which was 1st order stream. Similarity analysis indicated that three groups were divided at the similarity level of 80%. One group was the streams influenced by wastewater and the other two groups were the pristine streams as the control, indicating that the stream health conditions are directly influenced by presence or absence of the point sources. Also, Pearson's correlation analysis showed that IBI values had negative correlation (r=0.899, p<0.001) with relative abundance of tolerance species, and had positive relation (r=0.890, p<0.001) with sensitive species. Overall, outcomes suggest that the point sources of the WTP might impact the species composition and ecological health, resulting in degradation of biological water quality.