• Journal of Industrial Convergence
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• v.8 no.1
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• pp.49-64
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• 2010

Penalty tax of basic law that has been revised in December 30, 2006 has been amended to tax 40 percent on no report and under-reporting in unjustifiable way. This revision is a punitive regulation that reflects the national tax service's will to not sit back and watch taxpayers' intentional tax evasion by imposing a heavier tax burden, and it raised penalty tax rate that has been applied leniently compared to foreign countries. Therefore, this study examines how changes in penalty tax rate affected faithful tax report and in what level the punitive penalty tax rate should be legislated so that the effect of the penalty tax rate can be maximized by performing empirical analysis on the effect on income tax rate reporting standard of self-employed businesses before and after the time the penalty tax rate increased dramatically from 33.3% to 300% based on the items.

• Journal of Korea Trade
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• v.25 no.5
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• pp.74-92
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• 2021

Purpose - Utilizing a large sample of Korean firms, this study examines international diversification impacts on corporate tax avoidance and whether firms affiliated with large business groups (known in Korean as "chaebol") reinforce the relationship between international diversification and tax avoidance. Design/methodology - This paper hypothesizes that 1) international diversification is likely to increase tax avoidance, 2) the positive effect of international diversification on tax avoidance is likely to be more pronounced for chaebol firms. We examine the hypotheses by using Korean firms listed in the Korean stock market between 2011 and 2016. We employ the number of foreign subsidiaries and the entropy index as proxies for international diversification and CASH ETR and GAAP ETR as proxies for tax avoidance. Findings - Our findings are summarized as follows. First, we have found that as firms are more internationally diversified, tax avoidance increases. It means that international diversification can be employed as a method of reducing the tax burden. Second, firms affiliated with chaebol are strengthened by the positive relation between international diversification and tax avoidance. It is interpreted that chaebol firms have more effective opportunities to reduce taxes than other firms. When entering foreign markets, they can share experience and resources to decrease taxation within the large business group. Originality/value - This study provides empirical evidence regarding the tax effect of international diversification. Unlike prior studies, international diversification is positively related to tax avoidance in Korea. In addition, we present additional evidence on the chaebol effects of international diversification on tax avoidance, in which they have an advantage to reduce taxes using transfer pricing through related party transactions, income shifting to low tax rate countries, and establishing subsidiaries in tax havens.

• The Journal of the Institute of Internet, Broadcasting and Communication
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• v.23 no.4
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• pp.157-164
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• 2023

This paper suggests O(n²) polynomial time heuristic algorithm for corporate tax structure optimization problem that has been classified as NP-complete problem. The proposed algorithm constructs tax tree levels that the target holding company is located at root node of Level 1, and the tax code categories(T_e) 1,4,3,2 are located in each level 2,3,4,5 sequentially. To find the maximum tax-relief path from source(S) to target(T), firstly we connect the minimum witholding tax rate _minr_w(u, v) arc of node u point of view for transfer the profit from u to v node. As a result we construct the spanning tree from all of the source nodes to a target node, and find the initial feasible solution. Nextly, we find the alternate path with minimum foreign tax rate _minr_fi(u, v) of v point of view. Finally we choose the minimum tax-relief path from of this two paths. The proposed heuristic algorithm performs better optimal results than linear programming and Tabu search method that is a kind of metaheuristic method.

• Journal of the Korean Institute of Navigation
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• v.19 no.3
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• pp.35-65
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• 1995

The development of Korean shipping industry is maybe defined into three development stages-industry fixing stage, industry coordinating stage, industry development stage-. The development of shipping industry has been depended on the geovernment/authority role such as shipping policy, system, law, rules and regulations. In 1983, Korean shipping industry reorganization and coordination by shipping authority have made our shipping industry on the stable condition together with each company's efforts. Today's world economic environment such WTO/UR negotiation results get this government role limited. According to the being reduced government role, each company's competitive advantage power becomes more important. Besides, korean shipping industry is exposed into the entire and bitter world competition. In order to win and prevent the world shipping competition, it is necessary to look out the competitive advantage power of Korean shipping industry. The first purpose of this study is the situation analysis for competitive advantage power of Korean shipping industry. The second is to compare with our shipping policies with foreign ones concerned with ship, cargo, crew, tax and others. But in order to compare with foreign shipping, this study need their shipping statistics data, this study has some limit of the foreign data. This study has been carried on the basis of the following items. 1. Shipping environment, 2. Ships and ship acquirement(shipbuilding/purchasing), 3. Oceangoing cargo and ship's stowage rate, 4. Human factor in shipping-crew, 5. The incomes and costs in finacial statements. We have some conclusions as following through the this study. First, Korean shipping industry environment-competitive disadvantage situation- has changed rapidly due to the shipping market opening, free market entering of foreign shipping. Second, Korean shipping is disadvantageous due to the high tax rate and financing conditions in connection with ship acquirement. In order to improve the competitive advantage power, the shipping tax system and ship financing conditions should be reviewed to profitable for owners. Third, but both world and Korean oceangoing cargoes quantity have been increased annualy, Korean ship's cargo stowage rate is being decreased. This is serious situation but Korean shipping take well use of foreign vessel with hire. It is recommended to take use of owner's vessel and hired ones in the long range view, considering the world shipping management. But the number of crew has been decreased by 2, 000~3, 000 annualy, it is desirable that the long sea-experienced crew have been increased. Almost of owners usauly complain the crew cost is the main obstacles to competitive advantage power. Human factor is the most important firm's asset. All owners should pay attention to this though, and invest the proper budget to training, education, welfare as much as possible. In the long run this effects could be feedback to owners. Fifth, We must improve the financial statements structure, that is, the first step is to increase income, the second is to decrease cost, the third is to increase income on the same cost, the fourth is to decrease cost on the same income. It is essential to find out what the urgent investment is and what unnecessary cost is. At last, in order to competite world shipping race, each shipping firm must try for himself to retain the power. The government/authority is no longer dependable. I believe that each firm's power will be the industry's power, the industry's power will be the nations's power.

• Management & Information Systems Review
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• v.29 no.3
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• pp.71-96
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• 2010

This article firstly reviewed Permanent Established(PE) concept of OECD and UN model tax treaty and compared it with that of Korean Corporate Income Tax Law(CITL). The various factors regarding profit like ways of deciding the local source profit, scope and calculation method which will be imputed to PE were also reviewed. Based on above, standard PE judgement basis and calculation method of local source profit were also studied by using actual cases in foreign corporation which performs plant construction & sales in Korea. Accordingly to properly solve the conflict regarding international tax and to protect the tax authority against the foreign corporation in Korea, by standing on equality, I now propose followings for the better concept of PE in Korea. Firstly, the article that a building site or construction or installation project constitutes a PE only if it lasts more than 6 months should be modified to reflect OECD model convention's criteria of 12 months. Second, the scope of 'subordinate attorney' which is regarded as PE under CITL is now including 'holding-delivery attorney', 'order attorney', and 'assurance attorney' as well as 'contract attorney'. This is overly limit the activities of foreign corporation. It had better be loosened only to include 'contract attorney' as OECD provisions. Third, the CITL limits the cases of preparatory and/or auxiliary place which is not regarded as PE, thus limit the foreign corporations' business by expanding the concept of PE. This had better be eased. Fourth, in deciding the amount of local source profits, the CITL stipulates to split the profits by the relevant contribution of transaction parties through 'profit split method'. To solve the conflict, the ways of profit split must be better clarified through providing object and detailed standard and basis.

• The Journal of the Korea Contents Association
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• v.10 no.10
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• pp.334-350
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• 2010

This study aims at investigating the possible effects on the tax accounting practices stemming from adopting the IFRS in financial reporting process. It also seeks for policy implications to help alleviate practical conflicts likely to arise from the inconsistencies between the existing tax law and the tax related IFRS provisions. The results of the survey analysis are summarized as follows: firstly, majority opinion is opposed to the fair value based revaluation of property assets as well as the application of immediate recognition of foreign currency translation gains/losses. It favors the existing provision on asset securitization which adopts sales transaction view. Secondly, most of the respondents oppose the proposed amendments which allows dual classification of lease contracts on the ground. Third, functional currency appears acceptable on a conceptual level, even though a deep concern is expressed regarding the practical feasibility of computing taxable income using financial statements translated on the basis of functional currency on a practical viewpoint. Fourth, many respondents support the existing convention of recognizing depreciation expenses for taxation purposes and are in favor of the separation of accounting and tax books on a long-term basis. Fifth, the majority opinion approves the maintenance of existing tax reconciliation system and the recognition of expenses related with the doubtful accounts on reporting basis. Finally, a concern is raised with regard to the added burden of practical job loads needed to comply with the proposed amendments.

• The Journal of the Korea Contents Association
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• v.21 no.4
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• pp.96-110
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• 2021

Korea is faced with the challenge of adapting to the world's fastest - growing low birthrate, aging society, and low growth with low interest rate era. With low fertility and aging population, the factors of financial income of health insurance are decreasing, and the increase of public interest in health, high cost medical technology and the development of medicine are leading to increase expenditure of health insurance. In this study, I will examine the strengthen protection of health insurance, financial stabilization, and fairness of medical care. First, the present status and limitations of health insurance were identified through domestic policy report, domestic and foreign literature, and precedent research. Second, the foreign health insurance policy measures to stabilize the finances were examined separately. Based on this study, in order to maintain sustainable health insurance through reinforcement and financial stabilization of health insurance, the current financial income structure of health insurance must be renovated. It will be necessary to expand government subsidies and discover new tax revenues. In addition, a policy to save finances by reorganizing the medical bill payment system and medical delivery system will also be needed.

• 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.

• Journal of Digital Convergence
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• v.19 no.12
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• pp.321-329
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• 2021

A measure of managerial ability was derived using DEA, a measure of management efficiency, and the correlation coefficient between discretionary accrual and non-discretionary accrual, net income and operating cash flow standard deviation was used as a proxy for income smoothing. verified. In addition, the manager's compensation was used by taking the natural logarithm of the cash compensation per manager. The analysis results are summarized as follows. The analysis period for hypothesis testing is from 2004 to 2017, as a result of the hypothesis analysis of the correlation with the level of manager's compensation, it was suggested that the income smoothing behavior decreased the performance-based compensation and increased the performance-controlled compensation. This can be said to be the result of indirectly confirming that additional compensation is differentially paid for income smoothing. This study has a contribution to the study by empirically analyzing whether income smoothing affects the relationship between managerial ability and managerial compensation. However, although a number of previous studies empirically analyzed that there are upper and lower bounds for manager compensation, there is limitations that could not be analyzed for asymmetric compensation due to income smoothing is expected to expand.

• Journal of the Society of Naval Architects of Korea
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• v.42 no.6 s.144
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• pp.673-678
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• 2005

IMO adopted ' International Convention for The Control and Management of Ships' Ballast Water and Sediments ' on February 13th 2004. According to this convention, a ballast water treatment system should be installed in all ships obligatorily up to a standard date. When the system is installed, economic propriety should be considered. The economic propriety analysis examines the profit of a relevant project which can be presented by a equation, (Profit) = (income) - (expense) - (tax). However, the ballast water system is not for the profit during the life cycle but for the satisfaction of the regulation. Therefore, the expense should be minimum against the profit. This study presents the LCC(Life-Cycle Cost) analysis for economic evaluation of several ballast water system of foreign products.