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Transfer pricing documentation
Mitriková, Stanislava ; Frýzek, Libor (advisor) ; Bušovský, Ladislav (referee)
This final thesis deals with transfer pricing documentation from the theoretical and practical point of view. The aim of the thesis is to evaluate the settings of transfer prices within fictitious company by using processed documentation The first chapter of the thesis deals with the main principles and approaches to transfer prices to the extent provided by the legal regulations in the Czech Republic. The second chapter deals with the concept of content and composition of the documentation from the point of view of the OECD, EU and CR. In the practical part of the thesis, the intra-group transactions are analyzed in the model documentation, whether they are in accordance with the arm´s length principle.
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The world of Post BEPS transfer pricing
Sadilová, Michaela ; Frýzek, Libor (advisor) ; Zídková, Hana (referee)
The aim of this diploma thesis is to analyze impacts of BEPS including Country-by-Country reporting on the business field and on the tax administration. The theoretical part describes the importance of the initiative of BEPS transfer pricing including its the updated package, Action 8-10. Next part describes and compares the actual transfer pricing regulations in the countries of Visegrad 4 and in Germany. The last part of the diploma thesis analyzes the current transfer pricing situations and the cases of multinational corporation such as Google and Starbucks and it is followed by chaptures analyzing possible advantages and disadvantages that will arise from the new statement of CBCR.
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Tax aspects of investment incentives
Králová, Simona ; Frýzek, Libor (advisor) ; Pšurná, Pavla (referee)
The subject of this work is the system of investment incentives in the Czech Republic and it focuses on income tax allowances. Based on an analysis of the investment incentives law, income tax law, practical experience of the taxpayers and tax specialists, treatment of the matter by the Ministry of Finance of the Czech Republic or the Ministry of Industry and Trade of the Czech Republic and case law, the aim of this work is to identify problematic areas of the individual regulations and thus provide guidance to the taxpayers on reducing the risk of loss of an investment incentive in the form of income tax allowance. This work is divided into two parts. The first part characterises investment incentives and their development. It discusses the investment incentives law and focuses on investment incentives in the form of income tax allowances. The second part of this work incorporates a practical application of the regulations and case law. In conclusion, the problematic areas of the individual regulations are pointed out and explained.
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Trust funds taxation and their practical use
Štrichová, Iva ; Frýzek, Libor (advisor) ; Peroutka, Vojtěch (referee)
This diploma thesis is focused on the analysis of trust funds taxation, which is being prepared in Czech Republic based on comparison with existing arrangements in Great Britain, Italy, Switzerland and France. In the first part terms relevant to trust fund problematics used in the following parts of the thesis are defined. Also Hague Convention is mentioned, since it explains function of trust funds in continental countries. In the second part, the focus is on the analysis of legal and tax arrangement in chosen jurisdictions with emphasis on taxation in individual situations. The last part deals with legislation of trust funds based on the new civil code. Key issue here is analysis of tax legislation concerning the trust funds taxation in the Czech Republic and a proposal of taxation possibilities on the basis of comparing it with existing taxation in chosen jurisdictions. At the end of this part, arrangement of trust funds, which is contained in Model Tax Convention on Income and Capital, is mentioned.
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Comparison of rules for the creation of tax bases in selected countries
Klusáčková, Hana ; Frýzek, Libor (advisor) ; Matějka, Václav (referee)
This diploma thesis deals with the corporate tax, specifically with the comparison of the rules for the creation of the tax base in the Czech Republic, Slovak Republic, Cyprus and the Netherlands. The target of the thesis is to find out major differences in the structure of the corporate tax base, to assess the profitability of the systems for foreign investors and to formulate the recommendations for the Czech Republic. The thesis describes the legislative regulations of the corporate taxes in particular countries. The comparative analysis and the summary of the results formulated in the final part of the thesis. Furthermore, statutory and effective tax rates are being compared, as well as the share of revenues from corporate tax on gross domestic product and on total tax revenues.
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Tax efficient acquisition structures in the Czech Republic and related case law of the Court of Justice of the EU
Jedlička, Petr ; Frýzek, Libor (advisor) ; Jelínek, Michal (referee)
This diploma thesis is dedicated to acquisitions of companies and analyses their tax aspect under the laws of the Czech Republic. From taxation aspects point of view the thesis also focuses on commercial and accounting impacts of relevant acquisitions. The main objective of the thesis is to identify, quantify and qualitatively assess tax implications for parties participating within the acquisitions. The thesis further aims at identification of legal forms of acquisitions in the Czech law system, the accounting analysis of the acquisition alternatives and analysis of court's practice relevant from taxation point of view. These sub-objectives also define to certain extent, field for analysis and assessment of the tax implications of particular acquisition structures.
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Transfer pricing in the case law of the Supreme Administrative Court
Králová, Simona ; Frýzek, Libor (advisor) ; Jelínek, Michal (referee)
Based on the analysis of selected decisions of The Supreme Administrative Court in the area of transfer pricing, this document aims at identifying the general interpretation principles of the law by The Supreme Administrative Court. It also provides taxpayers with guidelines how to interpret the law and act in practice. The work is divided into three parts. The first part introduces legal regulations in the Czech Republic that relate to transfer pricing. In the second part, selected decisions of The Supreme Administrative Court in the area of transfer pricing are analysed. In the third part, the identified principles are formulated.
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