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Finanční transakce z pohledu transferových cen: cash-pooling
Glajšeková, Veronika
Glajšeková, V. Financial transactions from a transfer pricing perspective: cash pooling. Bachelor thesis. Brno: Mendel University, 2023. The bachelor thesis deals with financial transactions in transfer pricing, with cash pooling as its main focus. The first part of the thesis deals with the theoretical substate of the issue. The aim of the thesis is to evaluate the effects of different cashpooling structures and the creditworthiness of the entities involved on the determination of the usual interest rates granted by the bank for credit/debit balances on the master account of the cash pooling structure.
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Selected matters covered by statutory provisions on shareholders protection as set out in the commercial code
Pokorná, Veronika ; Štenglová, Ivanka (advisor) ; Dvořák, Tomáš (referee) ; Macek, Jiří (referee)
This dissertation looks at selected matters covered by the statutory provisions on the shareholders protection as set out in the Commercial Code. It focuses mainly on the matters contained in Section 196a of the Commercial Code, Section 193 (2) of the Commercial Code, and on the issue of financial assistance. In addition, this dissertation deals with the legal protection of shareholders under the Business Corporations Act which is to take effect on 1 January 2014, and provides a brief outline of how these matters are regulated under certain foreign laws. As well, it provides a comparison with the legal regulations of the European Union. This dissertation is comprised of three sections, each having several parts. The parts are further divided into articles. Section 1 analyses the statutory provisions on the protection of shareholders as given in the Commercial Code, and is divided into four parts. The introduction, given in Part I, focuses on the protection of shareholders under the Commercial Code in the general sense. The remaining three parts concentrate on the above said selected statutory provisions. In each of those three parts, I attempt to discuss the key purpose of the provisions, describe how they developed including respective amendment (novelizations) of the Commercial Code and, in this context,...
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Issues of Transfer Pricing
Radikovská, Daniela ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
ISSUES OF TRANSFER PRICING Transfer pricing has been often-discussed topic in recent years which is unlikely to change in the upcoming years. Given the great importance of transfer pricing in international tax planning, as well as in so called aggressive tax planning, it is a priority for states to set transfer pricing rules based on the arm's length principle in such a way that untaxed profits are not transferred from the jurisdictions where it was generated. Although this is a tax issue concerning the direct taxation, it shall be regulated at least in a coordinated manner by most countries in the world, as the international overlap is the greatest danger to state treasuries. From the perspective of taxpayers, it is often very difficult to meet all obligations regarding the setting of transfer pricing pursuant the arm's length principle, but it can be pointed out that a sufficiently clearly specified rules may be in favor of the taxpayers, because unjustified price manipulation between the related parties may cause some distortion of the functioning of the market. The main purpose of this thesis is to provide a comprehensive overview of transfer pricing issues from the perspective of Czech legislation, especially the Income Tax Act and instructions issued by the Ministry of Finance and the...
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Selected matters covered by statutory provisions on shareholders protection as set out in the commercial code
Pokorná, Veronika ; Štenglová, Ivanka (advisor) ; Dvořák, Tomáš (referee) ; Macek, Jiří (referee)
This dissertation looks at selected matters covered by the statutory provisions on the shareholders protection as set out in the Commercial Code. It focuses mainly on the matters contained in Section 196a of the Commercial Code, Section 193 (2) of the Commercial Code, and on the issue of financial assistance. In addition, this dissertation deals with the legal protection of shareholders under the Business Corporations Act which is to take effect on 1 January 2014, and provides a brief outline of how these matters are regulated under certain foreign laws. As well, it provides a comparison with the legal regulations of the European Union. This dissertation is comprised of three sections, each having several parts. The parts are further divided into articles. Section 1 analyses the statutory provisions on the protection of shareholders as given in the Commercial Code, and is divided into four parts. The introduction, given in Part I, focuses on the protection of shareholders under the Commercial Code in the general sense. The remaining three parts concentrate on the above said selected statutory provisions. In each of those three parts, I attempt to discuss the key purpose of the provisions, describe how they developed including respective amendment (novelizations) of the Commercial Code and, in this context,...
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Transfer pricing between related parties and its issues
Čech, Prokop ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Transfer pricing between related parties and its issues As the globalization of the world continues, and as the companies are merging into multinational enterprises, the number of transactions between related parties under circumstances that would not be concluded between unrelated parties is rising. The correct application of transfer pricing between related parties ensures that the transactions are concluded as it would have been between unrelated parties. More and more attention is paid to issue of transfer pricing, frequently in connection with tax planning and tax optimization, which is partly misleading. The tax consequences of transfer pricing are nonetheless substantial. The purpose of this thesis is to analyse transfer pricing issues in the Czech Republic in the context of international rules and standards as set by international organizations, mainly Organization for Economic Cooperation and Development (OECD), United Nations (UN) and European Union (EU), primarily from the tax perspective. The thesis is composed of 11 chapters. In first chapters the thesis describes the basics of transfer pricing, the concept of related parties, arm's length principle, transfer pricing methods and transfer pricing documentation. The next chapters are mainly focused on international transfer pricing...
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Transfer pricing documentation
Aubrechtová, Kamila ; Jurečka, Jan (advisor) ; Kačírková, Eliška (referee)
This thesis deals with the issue of transfer pricing, current legislation and methods with emphasis on the creation of transfer pricing documentation. The importance of documentation is mainly to show that prices in transactions between related parties do not differ from the prices agreed between independent parties. The thesis is divided into two main parts, theoretical and practical. The first chapter of this part deals with the definition of the concept of transfer pricing. The second chapter describes the current legislation of transfer pricing, both from the perspective of international regulation, but also in terms of the requirements in the Czech Republic. The following chapters are dedicated to the definition of arm's length principle and methods that can be used in the creation of transfer pricing. The following describes the meaning and way of creating transfer pricing documentation. The practical part deals with creating transfer pricing documentation with application to a particular company in order to verify compliance with the arm's length principle.
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Thin capitalisation in Czech Republic
Flaška, Ondrej ; Francírek, František (advisor) ; Roun, Vlastimil (referee)
This diploma thesis deals with thin capitalisation rules in the Czech Republic. The main objective is to analyze tax-deductibility of financial costs connected with loans from related parties. Czech Republic has been member of EU since 2004. The EU membership established the responsibility for Czech Republic to approximate national legislation of taxation with EU law, so the second objective of the diploma thesis is to consider how the Czech Republic deals with harmonisation of tax-deductible financial cost connected with loans from related parties.
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Thin Capitalization - The Influence of Tax Legislation on Employment of Debt Financing of Companies
Kočer, Petr ; Jurečka, Jan (advisor) ; Juppa, Martin (referee)
The aim of this thesis is to find out the answer to the question whether the state authorities influence the employment of debt financing of companies. First part of the work briefly summarizes the main economic theories engaged in the research on capital structure. Further are depicted approaches to thin capitalization in the European countries with focus on the Czech republic tax law dealing with the subject. The final part of the thesis demonstrates on the financial data of Czech companies from the period 2003-2008 that the state authorities influence the employment of debt in Czech companies by means of tax laws and so affect the capital structure of the companies.
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