• Korean Business Review
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• v.11
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• pp.319-341
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• 1998

Transfer pricing is a process for determining the prices of products, technology and services among affiliated companies. Although taxation problems arising from international investment are not now, they have become more important in recent years as a consequence of the growing internationalization of economic activities. So, trans pricing to shift their income and expenses from one country to another has made it difficult for tax administrations to impose tax collectly. Our government also applies arm' length methods to decide equitable tax. In the case of intangibles, because of the characteristics of the market, it is not easy to find the comparable uncontrolled transactions and it is almost impossible to apply cost=plus method or resale price method. This paper treats these problem, examining U.S. regulations and OECD guidelines and analysing the practice of transactions and the application of other methods.

• International Journal of Computer Science & Network Security
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• v.22 no.1
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• pp.300-304
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• 2022

The central feature of a digital society is the presence of a significant volume of digital services. The main research-analytical goal of the work is to identify the characteristic features of digital services, to classify and compare various types of digital services, to study the main levers for the development of digital services, the principal determinants of the observance and implementation of digital rights, to identify the dominant threats regarding the violation of digital rights, to analyze the features of legal relations that arise between the supplier and the consumer of digital technologies, consider the available taxation options for the digital economy. The work uses the following methods and research methods: hermeneutic, forecasting, in particular, extrapolation, analysis and synthesis, comparative. Research results: the definition of the concept of "digital service" is given, its main characteristics and types, according to the level of digitalization, the states-leaders are identified, slowing down, promising and problematic, the main triggers of slowing digitalization in some EU countries are investigated, by analyzing the regulatory legal acts of the European Commission on digitalization the strategy of the EU's actions to increase the degree of digitalization was determined, the positive and negative effects of digital services concerning the observance of human rights and freedoms were highlighted, the issue of levying taxes from digital companies was investigated.

• Journal of the Korean Society for Aviation and Aeronautics
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• v.23 no.3
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• pp.42-52
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• 2015

Since the tax-free system for overseas laborers was implemented in 1974, the tax-free limits of international air crew, overseas construction workers and crewmen of deep-sea fishing ships and ocean-going ships had been identical by 2005, but there are big differences, currently. The Ministry of Strategy and Finance pointed out the poor working environments and international competitiveness of the industries to explain the reason for the differential tax-free limit. From this perspective, the fairness of the tax-free system for overseas laborers was analyzed. This is an empirical study, based on the objective fact. The study finding showed that international air crew were working in the structural flight work environments to threaten the right of health due to jet lag and excessive exposure to high-altitude cosmic radiation. Therefore, it was analyzed there should be a proper system reform to apply the tax-free limits to international air crew which are identical to those applied to overseas construction workers and crewmen of deep-sea fishing ships and ocean-going ships, for a fair taxation.

• International Journal of Computer Science & Network Security
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• v.21 no.5
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• pp.43-47
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• 2021

In the course of this article, the concept of "innovation" was considered and analyzed, which is considered not only as a subject, something new, but also as a process. The process of introducing something new into life, and in our case, into the educational process. Innovative educational technologies are varied and plentiful. In this article, the most commonly used. Among them: the use of ICT, game techniques, the portfolio method, personality-oriented, information support of the learning process, educational and health-saving technologies, and others.

• 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 Information Technology
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• v.4 no.1
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• pp.23-37
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• 2001

There is no doubt that electronic commerce facilitates international trade and lower transaction cost and help firms make the best of the opportunities of market access. The comprehensive programs had been implemented to provide better electronic commerce environments by international organizations such as OECD, UNCITRAL, APEC and etc. Especially, WTO plays the most important role to implement efficient forms and rules on electronic commerce after Seattle 3rd Ministerial Conference. Member countries recognize the need to conduct the electronic commerce in compliance with the principles and rules of WTO. However, there are many issues to be solved such as the clarifications of concepts and definitions, the possibility of adaptation of technological neutrality In GATS, the Imposition of taxation in electronic commerce transactions and the methods of protecting copyright as well as trademark. The Implementation of concrete forms and rules of electronic commerce in the WTO will be influential to international trade as the member countries have to adapt them In their transactions. Considering that further discussion will be continued in GATS, we need to analyze the problems and strategies for electronic commerce.

• THE INTERNATIONAL COMMERCE & LAW REVIEW
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• v.59
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• pp.3-26
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• 2013

The purpose of this paper is to examine the several points at issue in international technology transfer contract from licensor's and licensee's perspectives, and to refer them when the licensor and the licensee draw up the contract. This author analyzed the critical points of the related provisions of ICC Model International Technology Transfer Contract(2009) by citing the explanations of the Introduction of the Model Contract. The provisions of the Model Contract are generally divided into two categolies; specific conditions and general conditions. This author selected four topics in the specific conditions; Contents of the Contract, Royalty, Modification and/or Improvements of Products, and Territory and Competition. Likewise this author selected three topics in the general conditions; Resolutions of Disputes, Applicable Law and Taxes. Both parties need to be mindful of the following points in the above topics, when they draw up the contract. First, both parties should make the definitions of special terminologies clear, which are included in the Contract. Second, before the parties sign the Contract, they should check any approvals to be necessary by the both countries' governments. Third, for the calculation of the royalty, they should clear the criteria, the scope, and the object. Fourth, as the local laws or regional laws regarding the territory limitation and taxation are mandatory, any provisions of the Contract should not be inconsistent with them. Therefore, both parties should check before-hand the local laws or rules related with the provisions of the Contract. Fifth, when the parties draw up the Contract, they should examine the Provisions of Dispute Resolution in consideration of the Governing Law. Thus both parties decide to make the technology transfer contract, the three aspects namely profitability, legal conflict with mandatory rules, and sustainability of the business resulting from the Contract should be examined in advance, and then proceed the business using the technology transfer.

• The Journal of Information Technology
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• v.7 no.1
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• pp.23-41
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• 2004

It is estimated that electronic commerce facilitates international trade and lower transaction cost and help firms make the best of the opportunities of market access. The comprehensive programs had been implemented to provide better electronic commerce environments by international organizations such as OECD, UNCITRAL, APEC, ICC and etc. Especially, WTO plays the most important role to implement efficient forms and rules on electronic commerce after Doha Ministerial Conference. Member countries recognize the need to conduct the electronic commerce in compliance with the principles and rules of WTO. However, there are many issues to be solved such as the clarifications of concepts and definitions, the possibility of adaptation of technological neutrality in GATS, the imposition of taxation in electronic commerce transactions and the methods of protecting copying as well as trademark. The Implementation of concrete forms and rules of electronic commerce in the WTO will be influential to international trade as the member countries have to adapt them in their transactions. Considering that further discussion will be continued in GATS, we need to analyze the problems and strategies for electronic commerce. As there are not concrete international laws for e-commerce, the existing laws must be revised and changed and each country need to present the enactment direction of e-commerce law to streamline e-commerce and to prevent trading partners from conflicting due to legal problems.

• Asia-Pacific Journal of Business
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• v.11 no.4
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• pp.205-224
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• 2020

Purpose - This study aimed to identify the effects of ownership structures on agency costs in internationally diversified firms listed on the KOSDAQ market. Design/methodology/approach - A total of 5,824 samples were finally selected and empirically analyzed for a total of nine years from 2011 to 2019, during which the International Accounting Standards had been mandatory for firms listed on the KOSDAQ market. Findings - The results of this study showed that the effects of ownership structures on the ratio of asset turnover are positive for the major share and foreign equity ratios of international diversified firms. Moreover, by selecting the ratio of entertainment expenses as a proxy for agency expenses, this study confirmed that the effects of the ownership structure of an international diversified entity on entertainment expenditure were determined to show a significantly negative relation to entertainment expenditure, thus indicating that the higher the ratio of major shareholders, the more appropriately control the expenditure of entertainment expenses through arbitrary private deviations of the management.Furthermore, considering the effect of the ownership structure on the expenditure of sales and administrative expenses as a proxy variable for agency costs, this study verified that the majority share ratio of international diversified firms was negative to the expenditure of sales and administrative expenses, confirming that the higher the share of major shareholders, the lower the selling and administrative costs, but insignificant.Finally, as a result of determining whether the ownership structure of an international diversified firm affects the holding of free cash, the majority share of this firm shows a significantly negative relation to the ratio of the holding of surplus cash, indicating that the higher the proportion of major shareholders, the more appropriately control the holding of the entity's free cash through arbitrary private deviance by the manager. Research implications or Originality - Major shareholders of an internationally diversified firm listed on the KOSDAQ market play a positive role in the firm's performance by properly controlling agency costs that may be incurred by the management.

• Korea Trade Review
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• v.46 no.6
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• pp.225-238
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• 2021

This study analyzed the recent precedents of the Korean Supreme Court's Royalty and License fee on this issue and presented implications for future taxation of Royalty and License fee and digital content imports related to reproduction rights. If the price related to imported goods and the price not related to them are combined, it is necessary to revise the statutes to supplement the allocation method of royalty and license fee. In addition, if there is an agreement or a back contract for intellectual property rights through the headquarters or branch office other than the trading party, a method of inducing the importer to voluntarily report it when reporting imports should be considered. Whether Royalty and License fee is taxed or not must be determined after examining the various contract details and circumstances of the transaction.