• 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 Korean Society of Forest Science
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• v.34 no.1
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• pp.31-46
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• 1977

The study was made to give some helpful information for policy-making on ornamental tree cultivation by doing a survey on general situations, management analysis, and future prospects of the ornamental tree growing. The study was carried out through literature studies related to the subject, questionaire surveys, and on-the-spot investigation. The questionaire surveys could be divided into two parts: pre-questionaire survey and main-questionaire survey. In the pre-questionaire survey, the researchers intended to identify the total number of ornamental tree growers, cultivation areas in size and their locations. The questionaires were sent to each town and county administration authorities, forest cooperatives, and related organizations through-out the nation. The main-questionaires were prepared for detailed study and the questionaires were sent to 200 tree growers selected by option by taking considerations of the number of tree growers and the size of cultivating areas in regions. The main findings and some information obtained in the survey were as follows: 1. The total land for ornamental tree growing was amounted to 1,873.02 hectares and the number of cultivators was totaled to 2,717. 2. The main occupations of the ornamental tree growers were found in horticulture (41.9%), agronomy (25.9%), officialdom (11.3%), animal husbandry (6.5%), business circle(4.8%), and forestry (3.2%) in sequence. 3. The ornamental trees were cultivated mostly upperland (54.8), forest land (19.4%), rice paddy (11.3%) and others. 4. The educational training of the tree growers seemed quite high. The results of the survey indicated that a large number of tree growers was occupied by college graduates (38.7%), and then high school graduates (34.7%), middle school graduates (12.9%) in order. 5. The tree farming was undertaken as a side-job (41.9%) rather than main-job (23.4%), but a few of respondents rated as subsidiary-job (18.6%). 6. The management status classified by the rate of hired labors used was likely to belong to three categories: independant enterprise management (41.9%); half independant management (31.5%); and self-management (32.4%). 7. The majority of the tree growers sold their products to the consumers through middle-man channel (48.4%), or directly to the house-holder and detailers (13.7%), but a few of the respondents answered that they disposed of their products by bidding (11.2%) or by direct selling to the contractors (4.8%). 8. The channel cf marketing seemed somewhat complicated. The results of the survey were as: (1) producers ${\rightarrow}$consumers (22.6%) (2) producers ${\rightarrow}$field middle-men${\rightarrow}$consumers (33.1%) (3) producers ${\rightarrow}$field middle-men${\rightarrow}$first stage brokers${\rightarrow}$consumers (15.3%) (4) producers ${\rightarrow}$field middle-men${\rightarrow}$second stage middle-men${\rightarrow}$brokers${\rightarrow}$consumers (5.7%) (5) producers${\rightarrow}$field middle-men${\rightarrow}$third stage middle-men${\rightarrow}$second stage middlemen${\rightarrow}$brokers${\rightarrow}$consumers (4.8%) 9. It was responded that the margin for each stage of middle-men or brokers was assumed to be 30-50%(33.1%), 20-30%(32.3%), 50-100%(9.7%), and 100-200%(2.4%) in sequence. 10. The difference between the delivery price of consumers and field selling price of the producers seemed quite large. Majority of producers responded that they received half a price compared to the consumer's prices. 11. About two thirds of the respondents opposed to the measure of "Law on Preservation and Utilization of Agricultural Land" in which says that all the ornamental trees grown on flat agricultural lands less than 8 degrees in slope must be transplanted within three years to other places more than 8 degrees in slope. 12. The tree growers said that they have paid rather high land taxes than they ought to pay (38.7%), but come responded that land tax seemed to be appropriate (15.3%), and half of the respondents answered "not known". 13. The measures for the standardization of ornamental trees by size were backed up by a large number of respondents (57.3%), but one third of the respondents showed negative answer (29.8%). 14. About half of the respondents favored the systematic marketing through organization such as forest cooperatives (54%), but quite a few respondents opposed to organizing the systematic marketing channel (36.3%). 15. The necessary measures for permission in ornamental tree cultivation was rejected by a large number of respondents (49.2%) than those of favored (43.6%).