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The lawful application of transfer pricing in business profession
Maděrová, Petra ; Francírek, František (advisor) ; Václavková, Jarmila (referee)
The diploma paper was focused on analysis of the tools -- it means documentation of transfer pricing and advance pricing arrangement leading to the higher tax bond of tax subject, for example: in the case of tax control. The main benefit of this diploma paper consists of analysis of primary data. These data were obtained from the questionnaire as well as from the interviews oriented mainly on tax control which I had led with 2 multinational companies. The questionnaire, which I had done by myself, was sent to 46 multinational companies which their business platforms are located also in the Czech Rep. The most valuable written sources from which some data for my diploma paper were taken is the real documentation of transfer pricing done for the request of advance pricing arrangement as well as the decision of tax administrator in the same case according to the § 38nc Law N. 586/1992 Sb., about income tax. Just the character of the data guarantees the practical application of this diploma paper. I hope according to my diploma paper to be successful in notice of absence in the basic instruments of transfer pricing from point of the multinational companies view which could lead to the adjustment by competent authorities. This adjustment could consequently improve the cooperation between tax subjects and tax authorities.
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Advance Pricing Agreements in The Czech Republic and chosen countries
Vítková, Klára ; Francírek, František (advisor) ; Jelínek, Michal (referee)
This diploma thesis operates with advance pricing agreements. In the Czech Republic, advance pricing agreements were implemented in the form of binding rulings in the year 2006. The goal of the thesis was to analyze and compare binding rulings in the Czech Republic and advance pricing agreements implemented in the countries chosen, which were Germany, Slovakia and Poland, with the theoretical concept of advance pricing agreements as stated in OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
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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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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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Comparison of Finnish and Czech Tax System
Papežová, Marcela ; Francírek, František (advisor) ; Roun, Vlastimil (referee)
The aim of this bachelor thesis "Comparison of Finnish and Czech Tax System" is to give readers more detailed information about both tax systems. The first descpriptive part shows a short summary of the progress of Tax system in Finland and then characterizes tax systems of the Czech Republic and Finland. The principal part is devoted to comparison of tax systems from different points of view. The main aim is to compare tax systems of both countries. I focus mainly on comparing the portion of particular taxes on total tax incomes, administrative demandingness during paying taxes and comparing of the tax destiny. I worked out accessible information and I concluded that the construction of tax systems is similar but each one is based on different parameters. Despite this fact some components of Finnish tax system we could transform into the Czech tax system.
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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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The comparison of czech and finnish tax system
Čejková, Jitka ; Francírek, František (advisor) ; Roun, Vlastimil (referee)
This bachelor thesis is focused on the comparision of the current tax system in Czech Republic and Finland. In the first part the theoretical principles of taxes in Czech Republic are explained, including the importance of individual taxes for the tax revenue. The Finnish taxes are described in the same way in the next chapter. The third part compares income tax in both countries as a real example, measures the taxes on consumption and matches the level of the real estate tax. The final fourth part clears up if the Czech tax system can be used in Finland and conversely.
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Problems of non-profit organizations tax income in Czech Republic
Beková, Radka ; Slintáková, Barbora (advisor) ; Francírek, František (referee)
The subject of my graduation theses is problems of non-profit organizations tax income in Czech Republic. My main goal is description and explication of problems of non-profit organizations tax income which I have been interested in. My component goal is an effort to formulate my own and already existing schemes of resolutions of the problems concerning effectiveness and tax income of non-profit organizations in Czech Republic. Non-profit organizations tax income is very complicated and inconclusive area of tax income.
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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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