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Creative accounting with impact on income tax
Kudláčková, Pavla ; Polák, Martin (advisor)
In this thesis I will try to clarify the concept of "creative accounting". I will engage in describing individual techniques that could lead to a wrong statement. Then, I will continue to identify more specific processes that affect the overall management. In conclusion, I work on reasons that lead to practices of creating accounting and also its consequences.
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Determination of transfer pricing using alternative methods
Kubešová, Lucie ; Francírek, František (advisor) ; Málek, Jiří (referee)
The focus of this thesis is alternative methods used to determine transfer pricing in practice, mainly in the environment where there is a lack of available comparable information in the market. The paper is divided into four chapters. The first lists basic terminology, available relevant legislation and briefly outlines particular methods of determining a transfer pricing as recommended by OECD directives and the use of those. The second chapter focuses mostly on identifying of an interval for transfer pricing acceptable for tax authorities under a sale of an enterprise or its part. The third chapter mentions further alternative methods for which the underlying asset for determining of transfer price are financial derivatives. The last chapter discusses the results of carried out analyses and presents recommendations to using alternative methods. The thesis contents are supported by a designed computer program, which is a key element for using the alternative methods in practice.
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Transfer pricing and binding rulings
Austerlitzová, Eliška ; Francírek, František (advisor) ; Roháček, Michal (referee)
Setting of transfer price, which is in line with arm's length principle and also with other legislature obligations, is currently with respect of limited experiences with such problematics very actual topic espetially with regard to possible impact. Institution of Billing Rulings of determination of transfer price is a newly established tool leading to legal confidence of tax payers and desireable step forward in Czech legislature. Evaluation of operation and usefulness of this tool is the main goal of my diploma thesis. Tax legisature includes also other editorial obligations of tax authority. Theire description is another objective of my thesis. Analysis of transfer pricing problematics is necessary for understandig the topic and therefore is a partial goal of my thesis. The full picture of transfer pricing Billing Rulings problematics with its aspects analysed on theoretical level is completed with practical example of application for Billing Rulings. The analysis of legislature lead to formulation of suggestions leading to better functioning of this institution.
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Transfer-pricing-based tax planning
Lhotský, Vladimír ; Buus, Tomáš (advisor) ; Kuncl, Karel (referee)
This work brings a systematic approach to the design of a transaction-based transfer-pricing policy of a multinational group and related tax optimization. The foundation of the work is a description and analysis of all aspect of the transfer-pricing regulation including a detailed classification of particular business risks. Using a certain simplification of the complicated relations in multinational groups, a system compliant with transfer-pricing rules is designed, hence minimizing the tax risk. Further, I devote my attention to rather complicated areas of transfer-pricing like pricing of payments for intangible property, pricing in non-standard structures and allocation of exchange rate risk. After the build-up of the architecture of the transfer-pricing system, analysis of the tax optimization possibilities adhering to all regulatory requirements is carried out. The detailed description of the tax effective supply chain management planning concept and other planning instruments is presented. The final part is devoted to the negative tax implications of business restructuring steps analyzed on the examples of particular structures.
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Accounting and tax aspects of different types of the foreign market entrance
Peciválová, Lenka ; Pelák, Jiří (advisor) ; Mezerová, Jana (referee)
The major topic of this thesis is tax and accounting aspects of different types of foreign market entrance. Basic types of foreign market entrance and their accounting and tax comprehension are defined in the first chapter. The second chapter is focused on legal point of view of the foreign entities business in Czech Republic and there are defined the main differences in foreign entities business by czech corporate entity and branch. The main differences of these subjects from the tax point of view are established in the third chapter, tax registration, tax duty origin, tax base, double taxation, mutual relations and transfer pricing. The fourth chapter is focused on the accounting duties both subjects, their differences and transactions accounting in practice of branch and its founder, foreign entity, in centralized and separated accounting system.
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Methods of determining transfer prices
Jurčíková, Kateřina ; Mařík, Miloš (advisor) ; Podškubka, Tomáš (referee)
Following thesis focuses on analysis of using five basic transfer pricing methods mentioned in the OECD Transfer Pricing Guidelines in the conditions of the Czech Republic (comparable uncontrolled method, resale-price method, cost plus method, profit split method, transactional net margin method). There are mentioned the problems connected with application of these methods and also suggestions how to fix them. In this respect thesis contains comparable, functional and economic analysis. As a part of the thesis there is an example of the transfer pricing documentation using cost plus method. Next there are noted the ways and criteria of selecting an appropriate method. There are also solved some tax aspects of determining the transfer prices.
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Methods of the transfer pricing identification in practise
Plešingerová, Jana ; Francírek, František (advisor)
This work focuses on methods of the transfer pricing identification, in connection with the possibility to find comparable independent data on the market. In the first part, the author describes the basic ideas and the main legislation resources both in the Czech Republic and internationally. It also describes the main methods of the transfer pricing identification mentioned in the Transfer Pricing Guideline. Second part examines the method's application, which depends mainly on the type of the controlled transaction as well as on the comparable data availibility. Third part relates to the model case, which shows in detail the complete process of the transfer pricing identification. Each process includes the functional analysis of related parties, choosing the best possible method and the comparable analysis, which focuses on the searching out the independent comparable companies.
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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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Analýza postupu správce daně při posuzování převodních cen mezi spojenými osobami
Vítková, Klára ; Vančurová, Alena (advisor)
Cílem bakalářské práce je zjistit metody a postupy, které v současnosti využívá český správce daně při posuzování převodních cen a zanalyzovat právní podmínky pro oblast převodních cen v České republice. Práce je rozdělena na dvě hlavní části. První část se zabývá legislativou převodních cen a jejím cílem je poskytnout přehled veřejně dostupné legislativní prameny, které se vztahují na převodní ceny v podmínkách České republiky. Druhá část má za cíl analyzovat postupy správce daně při daňové kontrole v souvislosti s převodními cenami prostřednictvím konkrétního skutečného případu.
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Tax aspects of business between associated enterprises -- stipulation of the method for distributive enterprise
Kuncová, Jana ; Jelínek, Michal (advisor)
This thesis "Tax aspects of business between associated enterprises -- stipulation of the method for distributive enterprise" considering associated enterprises and transfer pricing, as they are defined by documents of European Union, OECD and Czech Republic. It compares the definitions of associated enterprises and the arm's length principle according to OECD and the law of Czech Republic. It gives the list of methods transfer pricing which are used when making the prices for transactions between associated enterprises. These methods are divided into traditional and profitable - it depends on the kind of transaction. In the last part of this thesis on the basis of the analysis of these documents I recommend the optimal method for transfer pricing for a concrete enterprise.
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