• 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.

• Korean Business Review
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• v.19 no.2
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• pp.23-46
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• 2006

In modern economic societies, individuals are governed by organizations and they managed their daily lives in one way or another. through such organizations. All activities of the organizations are carried out by the job performance of individuals. Job is a very important factor for both individuals and organizations. The study is the explore. the effect of job characteristics and organizational characteristics on the job satisfaction in the small- and medium- sized firms in Namdong und Banwool Area. Job characteristics and organizational justice were hypothesized to be positively related to job satisfaction. To examine the influence of job characteristics and organizational justice on job satisfactions, data were collected from 320 employees of the small- and medium- sized manufacturing companies in Namdong und Banwool Area. This research took independent variables as the core job characteristics of the job characteristic theory such as skill variety, job stagnation, job importance, autonomy, feed back, and organizational justice as distributive and procedural justice. As a result, I can make the following suggestions. First, The Results show that job characteristics and organizational justice were significant and important predictors of job satisfaction. Secondarily, to raise the job desire of organizational members, job must be designed in such a way that the members can highly recognize their job characteristics.

• Journal of Platform Technology
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• v.9 no.4
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• pp.10-31
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• 2021

The digital tax, recently referred to as the Google tax was finally agreed at the 31st General Assembly of the OECD (October 8, 2021) with full support by 136 countries and will take effect from 2023. The purpose of this study is to analyze the digital tax prepared by the OECD for global MNEs, and to suggest the impacts on the Korean industry and to present the Korean governmental countermeasures. As the first study, we analyzed the international agreement on digital tax. In results, we found that even if global MNEs do not set up a business operation in overseas countries, if sales and profits are generated, 25% of the excess profit is borne as tax (pillar 1), and when MNEs do business in all the countries, they are liable to at least a 15% tax (pillar 2). We think that countries around the world have prepared a minimum countermeasure to protect their companies in anticipation that global MNEs will easily encroach on their markets in the future. As the second study, in order to discover the reason why the MNEs are so strong, we investigated the trends of Google and B2B SaaS companies in details. In results, we discovered that the global MNEs establishes a digital platform partnership ecosystem that enables them to enter foreign markets easily and expand rapidly. In conclusion, as a countermeasure for the Republic of Korea, governmental policies were proposed at the corporate (startup nurturing), industry, and national level respectively.