National Repository of Grey Literature 2 records found  Search took 0.00 seconds. 
Daňové aspekty soudních sporů v oblasti převodních cen
Volný, Karel
The aim of this thesis is to deduce the consequences of the tax aspects of transfer prices to the taxpayer based on the analysis of selected lawsuits in the area of transfer pricing and case law in this area issued by the Supreme Administrative Court of the Czech Republic (or the EU Court of Justice). The literature review describes the basic concepts, relationships and the transfer pricing legislation. My research deals with the analysis of selected lawsuits as well as with derivation of conclusions from analysing these lawsuits which provide the reader with an overall guide - what has been the court in certain field solving, what has been decided and what should the taxpayer and the tax administrator beware of. Conclusion of the case law is related to specific areas of its usage (rent, production, loans) as well as to the common universal principles - for instance allocation of the burden of proof, the importance of expert opinions or the procedure of calculation of prices.

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