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The impact of transfer price of enterprise on the corporate tax
Vágner, Jiří ; Francírek, František (advisor) ; Khazarova, Sofya (referee)
This thesis is focused on the sale of the enterprise between related persons. The ambition was to find out, what the tax aspects of a particural transfer of an existing company are, especially with regard to the payment of personal and corporate income tax rate. Partial aim was to determine market value of the enterprise as per January 1st 2010 for the transfer price purposes and structuring of the whole transaction with emphasis on rational tax optimalization. At first there is a valuation report elaborated with regard to the market environment. The price is set based on the DCF entity method. Consequently I work with the enterprise value analysing tax impacts. The transaction structure is chosen as setting up of a new company for leveraged buyout (SPV, s.r.o.) and subsequent merger of this company with the target company as per January 1st 2010. It was found out that the impact of the transfer price on the income tax is at this transaction minimal. In the particural structured transaction there are four kinds of tax risks. First are the rules of thin capitalization which the buyer is able to fulfil by the increase of its own capital at SPV, s.r.o. The second one is the assesment of interests on the affinitive credits according to the arm's length principle. The third one is check of costs of the acquisition credit which should be tax deductible with regard to the company merger. The last risk is the proof of accomplishment of general rules of costs (interest) tax deduction, i.e. the costs must be spent on achievement, securing and maintenance of taxable incomes. At the close of the thesis I focus on the motives of the related parties of the transaction for setting the price of the company. I assume that both parties would have tendencies to decline the enterprise value mostly because of the possibility of compensation through the gratuitous acquisition of asset which in this case in the legal environment of the Czech Republic enjoys the tax-free status.
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Mergers - accounting aspect according the czech legislative and tax framework
Kataeva, Natalia ; Vomáčková, Hana (advisor) ; Dvořáková, Dana (referee)
The main goal of my diploma is to describe domestic mergers and amalgamations, which take place on the territory of Czech republic. Chapters are divided and sorted by particular related areas of the czech legislative framowork. First part of my diploma is dedicated to mergeres as they are, their definition and basic characteristic.Then come description of mergers from different standpoints: legal, tax and account principles regarding to realized changes in framework legislation. A separate chapter describes the whole process of merger paying higher attention to obligatory steps and defined statuory terms. One of the chapters describes a process of merger as it is defined by IFRS rules and compares it with how it is defined by czech legislative framework. The last chapter is about showing an example on how two companies are merged.
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Financial analysis of firm Madeta a.s.
John, Vladimír ; Boukal, Petr (advisor) ; Klečka, Jiří (referee)
The aim of this work is to assess the financial stability of the company from 2003 to 2007. Period, when the company passes through a series of dynamic changes. Entry to the EU. The planned mergers in 2006. The work is divided into two parts. Methodological apparatus is described in the first part. In the second part this apparatus is applied to in practice.
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Taxation of multinational companies
Fajtová, Hana ; Klazar, Stanislav (advisor) ; Láchová, Lenka (referee)
This diploma thesis focuses on tax aspects of multinational companies. In the first part there is an analysis of EU Council Directive (relating multinational companies) compared with The Income Tax Law. Practical application of some of the above mentioned Directives is shown in some examples. The next part deals with very discussed and actual problem of multinational companies - transfer pricing. This thesis analyses particular documents for this area. The aim of this diploma paper is to create the copmlex thesis about taxation of multinational companies.
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The consolidation trend in banking
Pavlova, Olga ; Janda, Karel (advisor) ; Witzany, Jiří (referee)
This work investigates quickly developing consolidation trend in banking. The first part of the work is devoted to the theoretical basis, definitions, reasons for mergers and acquisitions, positive and negative consequences of consolidation. Special attention is paid to banking mergers and acquisitions (M&A), to their financing and regulation. The second chapter examines banking M&A process in detail, including models, which could be used during particular stages. The third chapter discusses development of the consolidation trend in Europe focused on Kazakhstan, Russia and Ukraine. The influence of the banking M&A on those countries' banking systems development is examined. Legal requirements and problems, which could occur in connection with banking M&A in these countries, are also discussed in this chapter. In the work were used some real banking M&A examples, illustrative examples for better understanding models, used in the M&A process, and case study as an illustration of the M&A process in the CIS countries.
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Cross-border mergers
Hubáčková, Marie ; Pelák, Jiří (advisor) ; Mezerová, Jana (referee)
This thesis deals with the topic of cross-border mergers in the Czech republic. In the introductory part, the expressions like merger, cross-border merger are explained and reasons and possible obstacles of the merger (cross-border mergers) execution described. In the following chapter, I mention the possibilities of cross-border mergers in the Czech republic up to now. The thesis also handles the influence of the Directive on cross-border mergers of limited lability companies and the Verdict of the European Court of Justice in the matter of sp. zn. C-411/03 SEVIC Systems AG on the final version of the new legal Act on Transformation of Companies and Cooperatives. In the next chapter, I deal with the legal, accounting and taxation aspects of the cross-border mergers under the current conditions and according to czech legislation. I also included a chapter about the control of mergers of competitors. The last chapter mentions a concrete example of the real first cross-border merger in the Czech republic.
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European banking mergers and its consequences
Hanzalík, Jan ; Půlpánová, Stanislava (advisor) ; Hradil, Dušan (referee)
The thesis reflects current issue of banking M&A in Europe and its consequences in the regulatory and supervisory area. The thesis sets a general topic of M&A into context of the banking industry. It drops the typology of consolidation entities, methods and reasons for consolidation. It examines the regulatory framework with accent on contemporary trends, namely the financial crisis and its impact into the regulatory and supervisory framework.
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Merger vs. fusion of company
Kravar, Jan ; Martiník, Karel (advisor)
The purpose of my bachelor thesis is to describe the subject of mergers from both legal and accounting point of view. The thesis is structured into ten parts which are further divided. Firstly, the basic characteristics of mergers are described, followed by their segmental classification and the main causes of their existence. The largest part of the thesis deals with mergers according to the Czech precept of law. Moreover, mergers are analyzed from the accounting point of view involving the perspective of both Czech accounting regulations and International accounting standards. Practical part of the thesis contains an example of the merger of two joint stock companies.
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The merger of Raiffeisenbank and eBank
Vejtasa, Radek ; Pelák, Jiří (advisor)
In my diploma thesis I consider a junction of Raiffeisenbank and eBank. The aim of this work is to introduce to the reader the Czech bank system and business transactions potential in the Czech Republic. I am also giving a detailed information on all processes which took its course during the merger of Raiffeisenbank and eBank, the causation of merger and following operation of associated bank.
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