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Strategies for determinig transfer prices in period of economical crisis
Skrbková, Lucie ; Francírek, František (advisor) ; Jakoubek, Jiří (referee)
In the most cases the market range of transfer pricing is determined from statistical data from previous years. In case of these data the time delay occurs when these data are collected and these data do not reflect if that are collected for period of economical growth or recession. As a result, the final transfer pricing range can become distorted. For this reason it is essential to be familiar with strategies and procedures that can be applied to "clean up" statistical data from the influence of business cycle fluctuations. These strategies and procedures are discussed in this diploma thesis. In the first theoretical chapter are presented transfer pricing issues, set the basic terms, analyzed basic available resources dealing with transfer pricing, defined methods for determining transfer pricing range and identified consequences of the economic crisis in relation to transfer pricing. The second chapter is focused on the selection of the most appropriate method for determining transfer pricing and comparative of both the theoretical and practical basis. The last chapter presents the strategies and procedures that can be used in a comparative analysis, in order to eliminate distortions of the statistical data from the influence of business cycle fluctuations.
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Aplication of transfer pricing in common companies
Kmoch, Daniel ; Francírek, František (advisor) ; Vančurová, Alena (referee)
This final work is trying to evaluate the administrative demands coming from the legal obligation of creating the documentation about the documentation about the transfer prices. In theoretical part autor is talking about the legal requirements for the mandatory documentation about the transfer pricing. In practical part autor is proposing the example of the mandatory documentation of transfer pricing form to existing company and is trying to reply to from what sources are this information coming and if it is about to create a new documents or to use the existing documentation. The conclusion of the work is to evaluate the final administrative demands coming from the obligation to setup the system of transfer pricing.
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Comparison of individual income taxes in the Czech Republic and Austria
Josková, Renata ; Francírek, František (advisor) ; Vančurová, Alena (referee)
This bachelor thesis is focused on the comparison of individual income taxes in Czech Republic and Austria, particularly on the personal tax levied on student's income. The theoretical part analyzes in detail structural elements of idividual income tax in both observed countries and describes conditions and obligations related to work activities of students. In the practical part of the thesis attention is payed to the calculation of tax liabilities of students, including comparison of the tax burden in these countries.
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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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