• 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.24 no.2
• /
• pp.125-148
• /
• 2018

Recently, as the demand for big data analysis increases, cases of analyzing unstructured data and using the results are also increasing. Among the various types of unstructured data, text is used as a means of communicating information in almost all fields. In addition, many analysts are interested in the amount of data is very large and relatively easy to collect compared to other unstructured and structured data. Among the various text analysis applications, document classification which classifies documents into predetermined categories, topic modeling which extracts major topics from a large number of documents, sentimental analysis or opinion mining that identifies emotions or opinions contained in texts, and Text Summarization which summarize the main contents from one document or several documents have been actively studied. Especially, the text summarization technique is actively applied in the business through the news summary service, the privacy policy summary service, ect. In addition, much research has been done in academia in accordance with the extraction approach which provides the main elements of the document selectively and the abstraction approach which extracts the elements of the document and composes new sentences by combining them. However, the technique of evaluating the quality of automatically summarized documents has not made much progress compared to the technique of automatic text summarization. Most of existing studies dealing with the quality evaluation of summarization were carried out manual summarization of document, using them as reference documents, and measuring the similarity between the automatic summary and reference document. Specifically, automatic summarization is performed through various techniques from full text, and comparison with reference document, which is an ideal summary document, is performed for measuring the quality of automatic summarization. Reference documents are provided in two major ways, the most common way is manual summarization, in which a person creates an ideal summary by hand. Since this method requires human intervention in the process of preparing the summary, it takes a lot of time and cost to write the summary, and there is a limitation that the evaluation result may be different depending on the subject of the summarizer. Therefore, in order to overcome these limitations, attempts have been made to measure the quality of summary documents without human intervention. On the other hand, as a representative attempt to overcome these limitations, a method has been recently devised to reduce the size of the full text and to measure the similarity of the reduced full text and the automatic summary. In this method, the more frequent term in the full text appears in the summary, the better the quality of the summary. However, since summarization essentially means minimizing a lot of content while minimizing content omissions, it is unreasonable to say that a "good summary" based on only frequency always means a "good summary" in its essential meaning. In order to overcome the limitations of this previous study of summarization evaluation, this study proposes an automatic quality evaluation for text summarization method based on the essential meaning of summarization. Specifically, the concept of succinctness is defined as an element indicating how few duplicated contents among the sentences of the summary, and completeness is defined as an element that indicating how few of the contents are not included in the summary. In this paper, we propose a method for automatic quality evaluation of text summarization based on the concepts of succinctness and completeness. In order to evaluate the practical applicability of the proposed methodology, 29,671 sentences were extracted from TripAdvisor 's hotel reviews, summarized the reviews by each hotel and presented the results of the experiments conducted on evaluation of the quality of summaries in accordance to the proposed methodology. It also provides a way to integrate the completeness and succinctness in the trade-off relationship into the F-Score, and propose a method to perform the optimal summarization by changing the threshold of the sentence similarity.

• Journal of Christian Education in Korea
• /
• v.71
• /
• pp.305-340
• /
• 2022

This study was started to suggest the direction of Christian educational development to revitalize North Korea's 'education' research. Since the two Koreas have experienced heterogeneity in almost all elements of society, such as politics, economy, society, culture, and education, during the period of division in 1977, true unification depends on laying the foundation for social integration that can overcome the sense of heterogeneity between the two Koreas. This is why North Korea's "education" research is needed. Education is the foundation for transferring culture and history, and for bringing about the survival, transformation, and community of society and since it is the mission of Korean churches and Christian educators to establish the direction of North Korean "education" research, North Korean "education" research is very important. Despite this importance, 'North Korean research' in the field of Christian education has not been properly conducted. Research on the "Christian Unification Education Program" that can be used in churches is actively taking place, but research on the macro level of presenting post-unification education blueprints is rare. This study was started to suggest the direction of Christian educational development to revitalize North Korea's 'education' research. For the study, the characteristics of 'North Korea Research' were analyzed according to generational classification. As a result of the study, recent research on North Korea has been expanding in research topics and methodologies, and recent studies have been differentiated into microscopic studies that deviate from existing research trends at a macro level and view North Korea's daily life. The characteristics of 'North Korean education research' are summarized by period. The research on North Korean education, which began in earnest in the 1970s, was divided into the period of start(70s), transition(80s), leap(90s), expansion(2000s), and development(2010s~). and research characteristics for each period were analyzed. Through this, early North Korean education research was also conducted in the policy aspect of the country, and the characteristics of political and social studies were strong, but recent studies have confirmed that the subjects and contents are diversifying. Based on these studies, the pending issues and issues of North Korean education research in the field of Christian education were analyzed. The study of North Korea in the field of Christian education, which began in the 1980s, has been conducted in the engineering aspect of 'development of unification education programs for churches'. However, studies on Christian unification education and North Korean education itself, which can be used in public education sites including Christian schools, have yet to be sufficient. Nevertheless, the diversification of research in the field of Christian education can be evaluated as a positive change. Based on these studies, it was proposed to establish a de-ideological research foundation, secure primary research data(Raw Data), activate research topics and research methodologies, and strengthen research capabilities in the direction of development to revitalize North Korean research in the field of Christian education. I hope this study will trigger various follow-up studies and help Korean churches that must achieve unification.

• Asia Marketing Journal
• /
• v.12 no.4
• /
• pp.27-54
• /
• 2011

This research attempted to present the efficiency of culture marketing to the organizations producing culture-art products and to the companies utilizing art and suggest the practical viewpoints to the culture and art policy agencies. The methodology used was to take an in-depth look at the consumer value cognition and benefits of culture-art products in contemporary consumption culture from a social context by conducting a total of 12 Focus Group Interviews, consisting of 58 males and females in their 10s~50s who can represent culture-art product consumers. The culture-art products refer to the artist's spiritual, actual act of creating or to the end products with economic exchange value. They are also sense goods and merit goods that affect the mental state of consumers. By looking at culture-art products as consumer merit goods, this research examined consumer value cognition of culture-art products based on the characteristics culture-art products. As a result, this research determined that consumers view culture-art products largely as 'aesthetic and sensuous merit goods', 'actual and individual merit goods', and 'social public property'. As 'aesthetic and sensuous merit goods', culture-art products are considered as the products of an artist's creative activities; as 'social public property', culture-art products have a public value in terms of ownership; and as 'actual and individual merit goods', culture-art products act on the spirit and reality of a consumer in terms of consumption. As a result of analyzing the benefits of culture-art products based on the above-mentioned consumer value cognition, it was observed that the benefits of culture-art-product consumption are chiefly divided into 'aesthetic character-oriented', 'social relationships-oriented', and 'individual benefits-oriented' depending on how consumers see culture-art products. A 3-conceptional structures model was constructed according to the relationship between consumer value cognition of culture-art products and the benefits. This research revealed that consumers who pursue the aesthetic value or sense of beauty as the central reason experience culture-art products themselves, enjoy intellectual quests, and pursue their satisfaction by expressing affection for and interests in culture-art products. On the other hand, consumers who pursue social value as the central reason as a means of communication by perceiving culture-art products as a public property of society, pursue sympathy with people close to them through the symbolic power of culture-art product consumption or the joy of self-display. Consumers who perceive art products as spiritual and actual merit goods and pursue consumer value as a central reason want to express their own personality, develop themselves, and differentiate themselves or identify themselves with others in the context of social relations for the ultimate goal of living a happy and satisfied life while pursuing to satisfy imminent and actual necessities as emotional stability and rest. The fact that culture-art product benefits could vary according to how a consumer perceives them implies that consumer value cognition of culture-art products and their benefits significant affect consumers' decision in choosing and consuming various culture-art products. It turned out that such benefits from the consumption of culture-art products reflect the complex contemporary consumption culture of rational consumption, symbolic consumption, experiential consumption, and social reflective consumption. This research identified conceptional structures of consumer value cognition on culture-art products and benefits that can be used for studying and understanding culture-art products consumers who pursue a variety of consumption values. They can also be used by private companies in utilizing art, as well as by national agencies in enhancing the population's quality of life. However, since this research could only conceptually grasp consumer perception of culture-art products and reveal the dimension of classification due to its own limitations arising from characteristic investigation, quantitative data on the benefits of culture-art product consumers should be measured in future studies through a quantitative investigation, while using the value cognition of culture-art products and the individual characteristics of consumers as variables based on this research.