• 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.

• KDI Journal of Economic Policy
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• v.13 no.4
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• pp.91-116
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• 1991

Market liberalization progressing simultaneously with high and rapidly rising domestic wages has created an adverse business environment for domestic firms. Korean firms are losing their international competitiveness in comparison to firms from LDC(Less Developed Countries) in low-tech industries. In high-tech industries, domestic firms without government protection (which is impossible due to the liberalization policy and the current international status of the Korean economy) are in a disadvantaged position relative to firms from advanced countries. This paper examines the division of roles between the private sector and the government in order to achieve a successful structural adjustment, which has become the impending industrial policy issue caused by high domestic wages, on the one hand, and the opening of domestic markets, on the other. The micro foundation of the economy-wide structural adjustment is actually the restructuring of business portfolios at the firm level. The firm-level business restructuring means that firms in low-value-added businesses or with declining market niches establish new major businesses in higher value-added segments or growing market niches. The adjustment of the business structure at the firm level can only be accomplished by accumulating firm-specific managerial assets necessary to establish a new business structure. This can be done through learning-by-doing in the whole system of management, including research and development, manufacturing, and marketing. Therefore, the voluntary cooperation among the people in the company is essential for making the cost of the learning process lower than that at the competing companies. Hence, firms that attempt to restructure their major businesses need to induce corporate-wide participation through innovations in organization and management, encourage innovative corporate culture, and maintain cooperative labor unions. Policy discussions on structural adjustments usually regard firms as a black box behind a few macro variables. But in reality, firm activities are not flows of materials but relationships among human resources. The growth potential of companies are embodied in the human resources of the firm; the balance of interest among stockholders, managers, and workers of the company' brings the accumulation of the company's core competencies. Therefore, policymakers and economists shoud change their old concept of the firm as a technological black box which produces a marketable commodities. Firms should be regarded as coalitions of interest groups such as stockholders, managers, and workers. Consequently the discussion on the structural adjustment both at the macroeconomic level and the firm level should be based on this new paradigm of understanding firms. The government's role in reducing the cost of structural adjustment and supporting should the creation of new industries emphasize the following: First, government must promote the competition in domestic markets by revising laws related to antitrust policy, bankruptcy, and the promotion of small and medium-sized companies. General consensus on the limitations of government intervention and the merit of deregulation should be sought among policymakers and people in the business world. In the age of internationalization, nation-specific competitive advantages cannot be exclusively in favor of domestic firms. The international competitiveness of a domestic firm derives from the firm-specific core competencies which can be accumulated by internal investment and organization of the firm. Second, government must build up a solid infrastructure of production factors including capital, technology, manpower, and information. Structural adjustment often entails bankruptcies and partial waste of resources. However, it is desirable for the government not to try to sustain marginal businesses, but to support the diversification or restructuring of businesses by assisting in factor creation. Institutional support for venture businesses needs to be improved, especially in the financing system since many investment projects in venture businesses are highly risky, even though they are very promising. The proportion of low-value added production processes and declining industries should be reduced by promoting foreign direct investment and factory automation. Moreover, one cannot over-emphasize the importance of future-oriented labor policies to be based on the new paradigm of understanding firm activities. The old laws and instititutions related to labor unions need to be reformed. Third, government must improve the regimes related to money, banking, and the tax system to change business practices dependent on government protection or undesirable in view of the evolution of the Korean economy as a whole. To prevent rational business decisions from contradicting to the interest of the economy as a whole, government should influence the business environment, not the business itself.

• Asia-Pacific Journal of Business Venturing and Entrepreneurship
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• v.10 no.5
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• pp.45-62
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• 2015

Entrepreneurial Orientation (EO hereafter) can be described as firm level entrepreneurial tendencies. Initially Miller(1983) clarifies the construct of EO, and defines an "entrepreneurial firm as one that engages in product marketing innovation, undertakes somewhat risky ventures, and is first to come up with proactive innovations, beating competitors to the punch". After Miller (1983), Covin & Slevin(1989) adopted EO as a uni-dimensional construct, and insisted that these three dimensions can be combined into a single scale. Since Covin & Slevin(1991), researchers including Lumpkin & Dess(1996) have explored the usefulness of EO. However not many attempts have been tried to summarize the results of previous empirical researches, and to suggest future research directions. To examine and find implications, current study classified the effects of EO as 1) main and mediating effects, 2) moderating effect, 3) other effects, and provide theoretical and empirical validation of EO, which suggested by Miller(2011). After analyzing research results published in major international and Korean journals in each research domain, current paper summarizes and evaluates previous research results, and then suggests research directions for the future. In doing so, we hope to provide some theoretical and practical insight for management of small and medium sized firms.

• Journal of Technology Innovation
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• v.21 no.2
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• pp.57-84
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• 2013

New product development(NPD) is imperative management activity for growth and survival of the firm. In the context of the small and medium-sized enterprises(SMEs), the firm became further dependent upon NPD with the increasing turbulence in environments. This research suggests the role of entrepreneurship orientation(EO) and absorptive capacity(ACAP) that affect the success rate of NPD in SMEs. Although each of them has been highlighted as critical resources in the aspect of the sustainable competitive advantage, the relationship and the effect between EO and ACAP have received scant attention. Based on the sample of 261 Korean SMEs, this study examines the direct/indirect effect of EO and ACAP on NPD performance. While innovativeness of EO has the direct effect on NPD performance, both risk-taking and proactiveness of EO show no significance. While realized ACAP has the positive influence on NPD performance, potential ACAP shows no significant influence. In addition, we found that the impact of innovativeness on NPD performance was being partially mediated by ACAP whereas the relationship between proactiveness and NPD performance being fully mediated by ACAP. These findings would provide generic insights that both exploration and exploitation regarding knowledge and resources in SMEs are necessary in order to increase NPD performance and two activities have to align with EO.

• Journal of the Korean association of regional geographers
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• v.14 no.5
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• pp.521-535
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• 2008

This paper aims to explore the spatial distribution and locational characteristics of the shipbuilding industry in the south-east region of Korea. The geography of the Korea's shipbuilding industry illustrates an absolute spatial concentration into the south-east region, including Gyeongnam, Busan and Ulsan. In view of the type of agglomeration, it is argued that the south-east region's shipbuilding industry has been evolved as an Advanced Hub & Spoke cluster, which is characterized by interconnected relationships between a couple of gigantic customer firms and the majority of small and medium-sized supplier firms. A survey on the locational factors of the firms presents that traditional locational factors, such as physical infrastructure, land, labour and industrial linkages, are more important than new economic geographical locational factors, such as knowledge, learning, innovation and networks. According to firm's evaluation of the Gyeongnam region's locational environments for the shipbuilding industry is, however, rather different to the result of firm's location decision factors. The shipbuilding firms in Gyeongnam see that the Gyeongnam region retains regional advantages in terms of agglomeration economies, geographical proximity to customers, the infrastructure of transportation and communication and the quality of life. On the contrary, firms recognize that the Gyeongnam region suffers from the lack of R&D and production workforce and a weak basis of industry-university -government networks.

• The Journal of the Korea institute of electronic communication sciences
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• v.7 no.4
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• pp.693-705
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• 2012

It is increasing the necessity of technology cooperation between nations, in the world, more and more. The international cooperation for the technology development have the dissipating effect of costs and risks and encourage efficient use of the knowledge and eventually help the firms better access overseas market easily. The S&T diplomacy of Korea is, at present, on international S&T cooperation to secure technologies to strengthen base of science, technology and innovation. This tendency is closely related with the governance issue in international S&T cooperation. And This international S&T cooperation is connected with the internationalization of firms. But it is getting more difficult for a firm, especially smaller firm like Korean SME to sustain the technological advantage over any significant period. The small and medium sized enterprises as Korean SME, internationalization of R&D is difficult just to think in terms of one framework with the limited accumulation of informations and experiences. So against that situation, this paper shows a new concept 'SME co-ordinator' as the role client(or player) reinforcing international S&T cooperation, sustaining the technological advantage for Korean SME. And 'SME co-ordinator' leads Korean SME to progress 'open innovation' not 'close innovation' as well as serving adequate information about appropriate partners and capable employer to help manage the international S&T cooperation for Internationalization of Industrial R&D for Korean SME.

• Asia pacific journal of information systems
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• v.22 no.1
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• pp.53-77
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• 2012

Financial firms, especially large scaled firms such as KB bank, NH bank, Samsung Card, Hana SK Card, Hyundai Capital, Shinhan Card, etc. should be securely dealing with the personal financial information. Indeed, people have tended to believe that those big financial companies are relatively safer in terms of information security than typical small and medium sized firms in other industries. However, the recent incidents of personal information privacy invasion showed that this may not be true. Financial firms have increased the investment of information protection and security, and they are trying to prevent the information privacy invasion accidents by doing all the necessary efforts. This paper studies how effectively a financial firm will be able to avoid personal financial information privacy invasion that may be deliberately caused by internal staffs. Although there are several literatures relating to information security, to our knowledge, this is the first study to focus on the behavior of internal staffs. The big financial firms are doing variety of information security activities to protect personal information. This study is to confirm what types of such activities actually work well. The primary research model of this paper is based on Theory of Planned Behavior (TPB) that describes the rational choice of human behavior. Also, a variety of activities to protect the personal information of financial firms, especially credit card companies with the most customer information, were modeled by the four-step process Security Action Cycle (SAC) that Straub and Welke (1998) claimed. Through this proposed conceptual research model, we study whether information security activities of each step could suppress personal information abuse. Also, by measuring the morality of internal staffs, we checked whether the act of information privacy invasion caused by internal staff is in fact a serious criminal behavior or just a kind of unethical behavior. In addition, we also checked whether there was the cognition difference of the moral level between internal staffs and the customers. Research subjects were customer call center operators in one of the big credit card company. We have used multiple regression analysis. Our results showed that the punishment of the remedy activities, among the firm's information security activities, had the most obvious effects of preventing the information abuse (or privacy invasion) by internal staff. Somewhat effective tools were the prevention activities that limited the physical accessibility of non-authorities to the system of customers' personal information database. Some examples of the prevention activities are to make the procedure of access rights complex and to enhance security instrument. We also found that 'the unnecessary information searches out of work' as the behavior of information abuse occurred frequently by internal staffs. They perceived these behaviors somewhat minor criminal or just unethical action rather than a serious criminal behavior. Also, there existed the big cognition difference of the moral level between internal staffs and the public (customers). Based on the findings of our research, we should expect that this paper help practically to prevent privacy invasion and to protect personal information properly by raising the effectiveness of information security activities of finance firms. Also, we expect that our suggestions can be utilized to effectively improve personnel management and to cope with internal security threats in the overall information security management system.

• Journal of Digital Convergence
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• v.11 no.10
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• pp.169-179
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• 2013

Small and medium-sized firms are increasingly dependent on the knowledge and expertise of the supply chain as a whole to innovate and improve supply chain performance. This research examines the capabilities that enable firms to collaborate successfully, and aims to identify the determinants of SCM performance of the suppliers participating in supply chains managed by Global Korean companies. This study proposes the technology support, the collaboration with tier two companies, incentives and information sharing as major research variables, and collected the survey responses from 58 domestics suppliers. The statistical results indicate that the incentives, technology support and the collaboration with tier two firms influence the level of co-work with the firm leading supply chain, and that information sharing has some impact on SCM performance of the suppliers. But on the contrary to our expectation, the co-work with the firm leading supply chain has only moderate impact on SCM performance with p value just over 5%. We conclude this paper with some suggestions for future research.

• Asia-Pacific Journal of Business Venturing and Entrepreneurship
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• v.7 no.3
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• pp.1-16
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• 2012

Under the international business circumstance, global supply chain management is considered a vital strategic challenge to small and medium-sized enterprises(SMEs) suffering from deficient resources and capabilities to exploit overseas markets comparing with large corporations. That is because they can expand their business domains into overseas markets by establishing strategic alliances with global supply chain partners. Although a wide range of previous researches have emphasized the cooperative networks in the chain, most are ignoring the importance of developing relational characteristics such as trust and reciprocity with the partners. Besides, verifying the relational factors influencing firms' export performances, some studies proposed different and inconsistent factors. According to the social capital theory, which is the social quality and networks facilitating close cooperation of inter-individual and inter-organization, provides the integrated view to identify the relational characteristics in the aspects of network, trust and reciprocal norm. Meanwhile, a number of researchers shows that global entrepreneurship is the internal and intangible resource necessary to promote SMEs' internationalization. Upon closer examination, however, they cannot explain clearly its influencing mechanism in the inter-firm cooperative relationships. This study is to verify the effect of social capital accumulated within global supply chain on SMEs' qualitative and quantitative export performance. In addition, we shed new light on global entrepreneurship expected to be concerned with the formation of social capital and the enhancement of export performances. For this purpose, the questionnaires, developed through literature review, were collected from 192 Korean SMEs affiliated in Korean Medium Industries Association and Global Chief Executive Officer's Club focusing on their memberships' international business. As a result of multi-regression analysis, the social capital - network, trust and reciprocal norm shared with global supply chain partner - as well as global entrepreneurship - innovativeness, proactiveness and risk-taking - have positive effect on SMEs' export performances. Also global entrepreneurship affects positively social capital which has mediating effect partially in the relationship between global entrepreneurship and performances. These results means that there is a structural process - global entrepreneurship(input), social capital(output), and export performances(outcome). In other words, a firm should consistently invest in and develop the social capital with global supply chain partners in order to achieve common goals, establish strategic collaborations and obtain long-term export performances. Furthermore, it is required to foster the global entrepreneurship in an organization so as to build up the social capital. More detailed practical issues and discussion are made in the conclusion.

• Journal of Korea Technology Innovation Society
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• v.21 no.1
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• pp.454-490
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• 2018

This paper examined the nonlinear relationships between external knowledge sources and the innovation performance of SMEs (small and medium-sized enterprises). Using 3,218 firm-year panel data in South Korea, this study found that increasing the number of external knowledge channels out of the value chain increases radical innovation. Meanwhile, increasing the number of external knowledge channels within the value chain increases the incremental innovation. Further, the external sources of knowledge both out of and in the value chain had inverted U-shaped relationships on radical and incremental innovation respectively. This finding implies that a mechanism of diminishing returns works in the relationship between the external sources of knowledge and innovation. The study also identified the synergistic effects between the external sources of knowledge out of the value chain and within the value chain, and confirmed that the synergistic effects strengthen the linear mechanism between the external sources of knowledge and innovation. In addition, this study found that the sources of knowledge both out of and within the value chain positively moderate the relationships between R&D investment and radical innovation of SMEs.