• 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.

• International Commerce and Information Review
• /
• v.15 no.4
• /
• pp.457-479
• /
• 2013

Through a Chinese rise, Chinese dream is actualizing as the world's great power. According to outlook of World Bank and IMF, Around 2030 China will be a great power bigger than America's economic power. The rise of China will give a huge impact to the whole world. China expands her influence through a global manufacturing base and a global market. To actualize 'Peaceful Rise' Strategy, China has many constraints. Chinese society is facing many difficult social problem due to side effects of a rapid development. Such as the spread of corruption, the severity of wealth gap, environmental degradation and energy shortage. Internationally there are containment from hegemon so-called 'China threat' dispute, Taiwan issue and territorial disputes. Western countries are hostile to China for two reasons. Based on expectations, one is China's socialist system and the other is the rising China which will compete for supremacy with Europe and America. Recent emergence of Chinese nationalism and the containment of the neighboring countries are also serious limiting factors. Domestically they have the rampant corruption in the bureaucracy, weakened capacity of Communist rule, wealth disparity due to the discriminatory economic development strategy, seriousness of rural problem, social instability, lack of social security systems and the development gap between the eastern coastal areas and western inland areas, ethnic minorities problems, the constraint of sustainable development issues due to lack of resources, environmental pollution and energy constraints. Like the former Soviet Union, China may face a dismantlement. After the rise, China may encounter possibilities of a war between great powers or a collapse of Chinese society caused by deepening internal conflict. Serious economic polarization would make peasants and urban workers, who are social vulnerable people, to turn their back to communist party and threaten the justification and the appropriateness of the ruling communist party. Chinese government will think internal system security threat is more formidable risk factor than a system security threat from the hegemon. The decline of great country comes from internal reasons rather than external reasons. To achieve peaceful rise, unification with Taiwan is an essential prerequisite. Taiwan issues are complex problems which equipped with international and domestic factors. Lack of energy resources, environmental pollution in China will bring economic crisis to Korean enterprises. Important influence to Korean economy will be a changeover of the method in economic development. It will turn the balance of investment and consumption, GDP-centered growth to consumption and environment-centered growth. Services industries including finance, environment, culture, education, health care and social welfare will grow. Change in China's growth model will give a great challenge upon the intermediate goods industry in Korea. Korea should reduce the portion of machinery, automotive, semiconductor, steel and chemical-centered export industry to China, and should increase the proportion of the service industry.