• 제목/요약/키워드: Analysis of means

Search Result 9,972, Processing Time 0.046 seconds

Pseudo Image Composition and Sensor Models Analysis of SPOT Satellite Imagery of Non-Accessible Area (비접근 지역에 대한 SPOT 위성영상의 Pseudo영상 구성 및 센서모델 분석)

  • 방기인;조우석
    • Proceedings of the KSRS Conference
    • /
    • 2001.03a
    • /
    • pp.140-148
    • /
    • 2001
  • The satellite sensor model is typically established using ground control points acquired by ground survey Of existing topographic maps. In some cases where the targeted area can't be accessed and the topographic maps are not available, it is difficult to obtain ground control points so that geospatial information could not be obtained from satellite image. The paper presents several satellite sensor models and satellite image decomposition methods for non-accessible area where ground control points can hardly acquired in conventional ways. First, 10 different satellite sensor models, which were extended from collinearity condition equations, were developed and then the behavior of each sensor model was investigated. Secondly, satellite images were decomposed and also pseudo images were generated. The satellite sensor model extended from collinearity equations was represented by the six exterior orientation parameters in 1$^{st}$, 2$^{nd}$ and 3$^{rd}$ order function of satellite image row. Among them, the rotational angle parameters such as $\omega$(omega) and $\phi$(phi) correlated highly with positional parameters could be assigned to constant values. For non-accessible area, satellite images were decomposed, which means that two consecutive images were combined as one image. The combined image consists of one satellite image with ground control points and the other without ground control points. In addition, a pseudo image which is an imaginary image, was prepared from one satellite image with ground control points and the other without ground control points. In other words, the pseudo image is an arbitrary image bridging two consecutive images. For the experiments, SPOT satellite images exposed to the similar area in different pass were used. Conclusively, it was found that 10 different satellite sensor models and 5 different decomposed methods delivered different levels of accuracy. Among them, the satellite camera model with 1$^{st}$ order function of image row for positional orientation parameters and rotational angle parameter of kappa, and constant rotational angle parameter omega and phi provided the best 60m maximum error at check point with pseudo images arrangement.

  • PDF

A Study on Developing Sensibility Model for Visual Display (시각 디스플레이에서의 감성 모형 개발 -움직임과 색을 중심으로-)

  • 임은영;조경자;한광희
    • Korean Journal of Cognitive Science
    • /
    • v.15 no.2
    • /
    • pp.1-15
    • /
    • 2004
  • The structure of sensibility from motion was developed for the purpose of understanding relationship between sensibilities and physical factors to apply it to dynamic visual display. Seventy adjectives were collected by assessing adequacy to express sensibilities from motion and reporting sensibilities recalled from dynamic displays with achromatic color. Various motion displays with a moving single dot were rated according to the degree of sensibility corresponding to each adjective, on the basis of the Semantic Differential (SD) method. The results of assessment were analyzed by means of the factor analysis to reduce 70 words into 19 fundamental sensibilities from motion. The Multidimensional Scaling (MDS) technique constructed the sensibility space in motion, in which 19 sensibilities were scattered with two dimensions, active-passive and bright-dark Motion types systemically varied in kinematic factors were placed on the two-dimensional space of motion sensibility, in order to analyze important variables affecting sensibility from motion. Patterns of placement indicate that speed and both of cycle and amplitude in trajectories tend to partially determine sensibility. Although color and motion affected sensibility according to the in dimensions, it seemed that combination of motion and color made each have dominant effect individually in a certain sensibility dimension, motion to active-passive and color to bright-dark.

  • PDF

Studies on the Comparative Analysis of Immunofunction of Agaricus blazei Murill Cultivated with Fermented Media Containing Pueraria thunbergiana (칡혼합 발효배지로 생산된 신령버섯의 면역기능성 비교 분석에 관한 연구)

  • 김주남;서정식;박동철
    • Food Science and Preservation
    • /
    • v.9 no.1
    • /
    • pp.114-119
    • /
    • 2002
  • This research was performed to investigate the immnomodulative effects of ploysaccharides extracted from the fruiting body of Agarcus blazei cultivated with the media which are fermented with sugar cane bagasse containing Pueraria thunbergiana in open-air storage. In MTT test, methanol extracts from the fruiting body of A. blazei cultivated with P. thunbergiana media showed in colon carcinoma line(HT29) by 1.5∼3.5 fold and human heptoma cell line (HepG2) by 1.3 ∼2.4 fold antitumor activites compared to two types media (rice straw plus sugar cane bagasse, rice straw only) often used in the fauns. To clarify the antimutagenic principles, three extracts, Ab-l, Ab-2 and Ab-3, were separated by the solvent fractionations such as hot water, cold & hot sodium hydroxide respectively, and their antimutagenic effects was determined against N-methyl-N'-nitro-N-cnitrso-guanidine(MNNG) using Salmonella typhymurium. There was no significant differencies of inhibition levels among the used media, but Ab-3 tractions still showed a high antimutagenicity in the Ames test regardless of cultivating areas or media. To prove the cell immunofunction, nitric oxide (NO) produced from Raw 264.7 matrophage cultured with three fractions (Ab-l, Ab-2, Ab-3) was measured, and showed generally increase about 45 ∼58 percent compared to another two media (rice straw plus sugar cane bagasse, rice straw only), in the fraction of hot alklai extracts of the fruiting body cultivated with P. thunbergiana, which means that the media selection could be very important factors for improving medicinal effects in agaricus blazei fruiting body.

Intelligent VOC Analyzing System Using Opinion Mining (오피니언 마이닝을 이용한 지능형 VOC 분석시스템)

  • Kim, Yoosin;Jeong, Seung Ryul
    • Journal of Intelligence and Information Systems
    • /
    • v.19 no.3
    • /
    • pp.113-125
    • /
    • 2013
  • Every company wants to know customer's requirement and makes an effort to meet them. Cause that, communication between customer and company became core competition of business and that important is increasing continuously. There are several strategies to find customer's needs, but VOC (Voice of customer) is one of most powerful communication tools and VOC gathering by several channels as telephone, post, e-mail, website and so on is so meaningful. So, almost company is gathering VOC and operating VOC system. VOC is important not only to business organization but also public organization such as government, education institute, and medical center that should drive up public service quality and customer satisfaction. Accordingly, they make a VOC gathering and analyzing System and then use for making a new product and service, and upgrade. In recent years, innovations in internet and ICT have made diverse channels such as SNS, mobile, website and call-center to collect VOC data. Although a lot of VOC data is collected through diverse channel, the proper utilization is still difficult. It is because the VOC data is made of very emotional contents by voice or text of informal style and the volume of the VOC data are so big. These unstructured big data make a difficult to store and analyze for use by human. So that, the organization need to automatic collecting, storing, classifying and analyzing system for unstructured big VOC data. This study propose an intelligent VOC analyzing system based on opinion mining to classify the unstructured VOC data automatically and determine the polarity as well as the type of VOC. And then, the basis of the VOC opinion analyzing system, called domain-oriented sentiment dictionary is created and corresponding stages are presented in detail. The experiment is conducted with 4,300 VOC data collected from a medical website to measure the effectiveness of the proposed system and utilized them to develop the sensitive data dictionary by determining the special sentiment vocabulary and their polarity value in a medical domain. Through the experiment, it comes out that positive terms such as "칭찬, 친절함, 감사, 무사히, 잘해, 감동, 미소" have high positive opinion value, and negative terms such as "퉁명, 뭡니까, 말하더군요, 무시하는" have strong negative opinion. These terms are in general use and the experiment result seems to be a high probability of opinion polarity. Furthermore, the accuracy of proposed VOC classification model has been compared and the highest classification accuracy of 77.8% is conformed at threshold with -0.50 of opinion classification of VOC. Through the proposed intelligent VOC analyzing system, the real time opinion classification and response priority of VOC can be predicted. Ultimately the positive effectiveness is expected to catch the customer complains at early stage and deal with it quickly with the lower number of staff to operate the VOC system. It can be made available human resource and time of customer service part. Above all, this study is new try to automatic analyzing the unstructured VOC data using opinion mining, and shows that the system could be used as variable to classify the positive or negative polarity of VOC opinion. It is expected to suggest practical framework of the VOC analysis to diverse use and the model can be used as real VOC analyzing system if it is implemented as system. Despite experiment results and expectation, this study has several limits. First of all, the sample data is only collected from a hospital web-site. It means that the sentimental dictionary made by sample data can be lean too much towards on that hospital and web-site. Therefore, next research has to take several channels such as call-center and SNS, and other domain like government, financial company, and education institute.

A Legal Study on liability for damages cause of the air carrier : With an emphasis upon liability of passenger (항공운송인의 손해배상책임 원인에 관한 법적 고찰 - 여객 손해배상책임을 중심으로 -)

  • So, Jae-Seon;Lee, Chang-Kyu
    • The Korean Journal of Air & Space Law and Policy
    • /
    • v.28 no.2
    • /
    • pp.3-35
    • /
    • 2013
  • Air transport today is a means of transport that is optimized for exchanges between nations. Around the world, has experienced an increase in operating and the number of airline route expansion that has entered into the international aviation agreements in order to take advantage of the air transport efficient, but the possibility of the occurrence of air transport accidents increased. When compared to the accident of other means of transport, development of air transport accidents, not high, but it leads to catastrophe aviation accident occurs. Air Transport accident many international transportation accident than domestic transportation accident, in the event of an accident, the analysis of the legal responsibility of the shipper or the like is necessary or passenger air carrier. Judgment of the legal order of discipline of air transport accident is a classification of the type of air transport agreement. Depending on the object, air transport agreements are classified into the contract of carriage of aviation of the air passenger transportation contract. For casualties occurs, air passenger transportation accident is a need more discussion of legal discipline for this particular. Korean Commercial Code, it is possible to reflect in accordance with the actual situation of South Korea the contents of the treaty, which is utilized worldwide in international air transport, even on the system, to control land, sea, air transport and welcoming to international standards. However, Korean Commercial Code, the problem of the Montreal Convention has occurred as it is primarily reflecting the Montreal Convention. As a cause of liability for damages, under the Commercial Code of Korea and the contents of the treaty precedent is reflected, the concept of accident is necessary definition of the exact concept for damages of passengers in particular. Cause of personal injury or death of passengers, in the event of an accident to the "working for the elevation" or "aircraft" on, the Montreal Convention is the mother method of Korea Commercial Code, liability for damages of air carrier defines. The Montreal Convention such, continue to be a matter of debate so far in connection with the scope of "working for the lifting of" the concepts defined in the same way from Warsaw Convention "accident". In addition, it is discussed and put to see if you can be included mental damage passenger suffered in air transport in the "personal injury" in the damage of the passenger is in the range of damages. If the operation of aircraft, injury accident, in certain circumstances, compensation for mental damage is possible, in the same way as serious injury, mental damage caused by aviation accidents not be able to live a normal life for the victim it is damage to make. So it is necessary to interpret and what is included in the injury to the body in Korea Commercial Code and related conventions, non-economic damage of passengers, clearly demonstrated from the point of view of prevention of abuse of litigation and reasonable protection of air carrier it must compensate only psychological damage that can be. Since the compensation of delay damages, Warsaw Convention, the Montreal Convention, Korea Commercial Code, there are provisions of the liability of the air carrier due to the delayed arrival of passenger and baggage, but you do not have a reference to delayed arrival, the concept of delay arrangement is necessary. The strict interpretation of the concept of delayed arrival, because it may interfere with safe operation of the air carrier, within the time agreed to the airport of arrival that is described in the aviation contract of carriage of passenger baggage, or, these agreements I think the absence is to be defined as when it is possible to consider this situation, requests the carrier in good faith is not Indian or arrive within a reasonable time is correct. The loss of passenger, according to the international passenger Conditions of Carriage of Korean Air, in addition to the cases prescribed by law and other treaties, loss of airline contracts, resulting in passengers from a service that Korean Air and air transport in question do damage was is, that the fact that Korean Air does not bear the responsibility as a general rule, that was caused by the negligence or intentional negligence of Korean Air is proof, negligence of passengers of the damage has not been interposed bear responsibility only when it is found. It is a clause in the case of damage that is not mandated by law or treaty, and responsible only if the negligence of the airline side has been demonstrated, but of the term negligence "for" intentional or negligent "Korean Air's Terms" I considered judgment of compatibility is required, and that gross negligence is appropriate. The "Korean Air international passenger Conditions of Carriage", airlines about the damage such as electronic equipment that is included in the checked baggage of passengers does not bear the responsibility, but the loss of baggage, international to arrive or depart the U.S. it is not the case of transportation. Therefore, it is intended to discriminate unfairly passengers of international flights arriving or departure to another country passengers of international flights arriving or departure, the United States, airlines will bear the responsibility for the goods in the same way as the contents of the treaty it should be revised in the direction.

  • PDF

The Effect of Retailer-Self Image Congruence on Retailer Equity and Repatronage Intention (자아이미지 일치성이 소매점자산과 고객의 재이용의도에 미치는 영향)

  • Han, Sang-Lin;Hong, Sung-Tai;Lee, Seong-Ho
    • 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.

  • PDF

A New Exploratory Research on Franchisor's Provision of Exclusive Territories (가맹본부의 배타적 영업지역보호에 대한 탐색적 연구)

  • Lim, Young-Kyun;Lee, Su-Dong;Kim, Ju-Young
    • Journal of Distribution Research
    • /
    • v.17 no.1
    • /
    • pp.37-63
    • /
    • 2012
  • In franchise business, exclusive sales territory (sometimes EST in table) protection is a very important issue from an economic, social and political point of view. It affects the growth and survival of both franchisor and franchisee and often raises issues of social and political conflicts. When franchisee is not familiar with related laws and regulations, franchisor has high chance to utilize it. Exclusive sales territory protection by the manufacturer and distributors (wholesalers or retailers) means sales area restriction by which only certain distributors have right to sell products or services. The distributor, who has been granted exclusive sales territories, can protect its own territory, whereas he may be prohibited from entering in other regions. Even though exclusive sales territory is a quite critical problem in franchise business, there is not much rigorous research about the reason, results, evaluation, and future direction based on empirical data. This paper tries to address this problem not only from logical and nomological validity, but from empirical validation. While we purse an empirical analysis, we take into account the difficulties of real data collection and statistical analysis techniques. We use a set of disclosure document data collected by Korea Fair Trade Commission, instead of conventional survey method which is usually criticized for its measurement error. Existing theories about exclusive sales territory can be summarized into two groups as shown in the table below. The first one is about the effectiveness of exclusive sales territory from both franchisor and franchisee point of view. In fact, output of exclusive sales territory can be positive for franchisors but negative for franchisees. Also, it can be positive in terms of sales but negative in terms of profit. Therefore, variables and viewpoints should be set properly. The other one is about the motive or reason why exclusive sales territory is protected. The reasons can be classified into four groups - industry characteristics, franchise systems characteristics, capability to maintain exclusive sales territory, and strategic decision. Within four groups of reasons, there are more specific variables and theories as below. Based on these theories, we develop nine hypotheses which are briefly shown in the last table below with the results. In order to validate the hypothesis, data is collected from government (FTC) homepage which is open source. The sample consists of 1,896 franchisors and it contains about three year operation data, from 2006 to 2008. Within the samples, 627 have exclusive sales territory protection policy and the one with exclusive sales territory policy is not evenly distributed over 19 representative industries. Additional data are also collected from another government agency homepage, like Statistics Korea. Also, we combine data from various secondary sources to create meaningful variables as shown in the table below. All variables are dichotomized by mean or median split if they are not inherently dichotomized by its definition, since each hypothesis is composed by multiple variables and there is no solid statistical technique to incorporate all these conditions to test the hypotheses. This paper uses a simple chi-square test because hypotheses and theories are built upon quite specific conditions such as industry type, economic condition, company history and various strategic purposes. It is almost impossible to find all those samples to satisfy them and it can't be manipulated in experimental settings. However, more advanced statistical techniques are very good on clean data without exogenous variables, but not good with real complex data. The chi-square test is applied in a way that samples are grouped into four with two criteria, whether they use exclusive sales territory protection or not, and whether they satisfy conditions of each hypothesis. So the proportion of sample franchisors which satisfy conditions and protect exclusive sales territory, does significantly exceed the proportion of samples that satisfy condition and do not protect. In fact, chi-square test is equivalent with the Poisson regression which allows more flexible application. As results, only three hypotheses are accepted. When attitude toward the risk is high so loyalty fee is determined according to sales performance, EST protection makes poor results as expected. And when franchisor protects EST in order to recruit franchisee easily, EST protection makes better results. Also, when EST protection is to improve the efficiency of franchise system as a whole, it shows better performances. High efficiency is achieved as EST prohibits the free riding of franchisee who exploits other's marketing efforts, and it encourages proper investments and distributes franchisee into multiple regions evenly. Other hypotheses are not supported in the results of significance testing. Exclusive sales territory should be protected from proper motives and administered for mutual benefits. Legal restrictions driven by the government agency like FTC could be misused and cause mis-understandings. So there need more careful monitoring on real practices and more rigorous studies by both academicians and practitioners.

  • PDF

Accounting Conservatism and Excess Executive Compensation (회계 보수주의와 경영자 초과보상)

  • Byun, Seol-Won;Park, Sang-Bong
    • Management & Information Systems Review
    • /
    • v.37 no.2
    • /
    • pp.187-207
    • /
    • 2018
  • This study examines the negative relationship between accounting conservatism and excess executive compensation and examines whether their relationship increases as managerial incentive compensation intensity increases. For this purpose, a total of 2,755 company-years were selected for the analysis of the companies listed on the Korea Stock Exchange from December 2012 to 2016 as the final sample. The results of this study are as follows. First, there is a statistically significant negative relationship between accounting conservatism and manager overpayment. This implies that managers' incentives to distort future cash flow estimates by over booking assets or accounting profits in order to maximize their compensation when manager compensation is linked to firm performance. In this sense, accounting conservatism can reduce opportunistic behavior by restricting managerial accounting choices, which can be interpreted as a reduction in overpayment to managers. Second, we found that the relationship between accounting conservatism and excess executive compensation increases with the incentive compensation for accounting performance. The higher the managerial incentive compensation intensity of accounting performance is, the more likely it is that the manager has the incentive to make earnings adjustments. Therefore, the high level of incentive compensation for accounting performance means that the ex post settling up problem due to over-compensation can become serious. In this case, the higher the managerial incentive compensation intensity for accounting performance, the greater the role and utility of conservatism in manager compensation contracts. This study is based on the fact that it presents empirical evidence on the usefulness of accounting conservatism in managerial compensation contracts theoretically presented by Watts (2003) and the additional basis that conservatism can be used as a useful tool for investment decision.

A Study on the Effect of Network Centralities on Recommendation Performance (네트워크 중심성 척도가 추천 성능에 미치는 영향에 대한 연구)

  • Lee, Dongwon
    • Journal of Intelligence and Information Systems
    • /
    • v.27 no.1
    • /
    • pp.23-46
    • /
    • 2021
  • Collaborative filtering, which is often used in personalization recommendations, is recognized as a very useful technique to find similar customers and recommend products to them based on their purchase history. However, the traditional collaborative filtering technique has raised the question of having difficulty calculating the similarity for new customers or products due to the method of calculating similaritiesbased on direct connections and common features among customers. For this reason, a hybrid technique was designed to use content-based filtering techniques together. On the one hand, efforts have been made to solve these problems by applying the structural characteristics of social networks. This applies a method of indirectly calculating similarities through their similar customers placed between them. This means creating a customer's network based on purchasing data and calculating the similarity between the two based on the features of the network that indirectly connects the two customers within this network. Such similarity can be used as a measure to predict whether the target customer accepts recommendations. The centrality metrics of networks can be utilized for the calculation of these similarities. Different centrality metrics have important implications in that they may have different effects on recommended performance. In this study, furthermore, the effect of these centrality metrics on the performance of recommendation may vary depending on recommender algorithms. In addition, recommendation techniques using network analysis can be expected to contribute to increasing recommendation performance even if they apply not only to new customers or products but also to entire customers or products. By considering a customer's purchase of an item as a link generated between the customer and the item on the network, the prediction of user acceptance of recommendation is solved as a prediction of whether a new link will be created between them. As the classification models fit the purpose of solving the binary problem of whether the link is engaged or not, decision tree, k-nearest neighbors (KNN), logistic regression, artificial neural network, and support vector machine (SVM) are selected in the research. The data for performance evaluation used order data collected from an online shopping mall over four years and two months. Among them, the previous three years and eight months constitute social networks composed of and the experiment was conducted by organizing the data collected into the social network. The next four months' records were used to train and evaluate recommender models. Experiments with the centrality metrics applied to each model show that the recommendation acceptance rates of the centrality metrics are different for each algorithm at a meaningful level. In this work, we analyzed only four commonly used centrality metrics: degree centrality, betweenness centrality, closeness centrality, and eigenvector centrality. Eigenvector centrality records the lowest performance in all models except support vector machines. Closeness centrality and betweenness centrality show similar performance across all models. Degree centrality ranking moderate across overall models while betweenness centrality always ranking higher than degree centrality. Finally, closeness centrality is characterized by distinct differences in performance according to the model. It ranks first in logistic regression, artificial neural network, and decision tree withnumerically high performance. However, it only records very low rankings in support vector machine and K-neighborhood with low-performance levels. As the experiment results reveal, in a classification model, network centrality metrics over a subnetwork that connects the two nodes can effectively predict the connectivity between two nodes in a social network. Furthermore, each metric has a different performance depending on the classification model type. This result implies that choosing appropriate metrics for each algorithm can lead to achieving higher recommendation performance. In general, betweenness centrality can guarantee a high level of performance in any model. It would be possible to consider the introduction of proximity centrality to obtain higher performance for certain models.

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
    • /
    • 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.