|
| |
|
| |
|
| |
|
|
Analysis of specific instruments applied in the financial management of TNC with a focus on transfer pricing
Baluchová, Daniela ; Taušer, Josef (advisor) ; Sato, Alexej (referee) ; Baláž, Peter (referee)
Transfer pricing plays a crucial role in the financial management of TNC as it significantly influences revenues and costs allocation among affiliates of TNC that are located in countries with different tax regimes, interest rates, political situation and economic environment. Recently, transfer pricing is scrutinized in respect of tax minimisation strategies adopted by TNC which raises various conflicts of interest with tax authorities in some countries of their presence. The main objective of the dissertation thesis is to provide a comprehensive empirical study on international transfer pricing in the Czech Republic from the perspectives of both taxpayer and the tax authority. With regard to the complexity of transfer pricing, manufacturing afiliates of TNC located in the Czech Republic were selected to be examined in more detail. The thesis is structured into five chapters. The first chapter defines theoretical framework based on which the analytical part of the thesis is elaborated. The strategies applied by TNC in setting transfer prices are strongly affected by the transfer pricing regulation and interpretative experience of the particular countries in which they operate. In this context, the Czech transfer pricing legislation as well as selected case law is analyzed in the second chapter. Given the complexity of the issue of transfer pricing, the third chapter deals with selected aspects that are considered critical when setting transfer prices. The fourth chapter presents key findings regarding transfer pricing strategies applied by TNC located in the Czech Republic to transfer pricing issues. The fifth chapter summarizes the approach of the Czech tax authorities to the transfer pricing audits and at the same time evaluates related risks borne for taxpayers in this respect. The thesis reveals that manufacturing afiliates of TNC located in the Czech Republic generally prefer non market (cost based) transfer pricing methods when setting transfer prices, whereby there are several factors influencing their decision making, out of which internal economic conditions and foreign exchange risk management are deemed the most important factors, while tax optimisation as well as restrictions on profit repatriation are considered relatively less important factors. The study further indicates certain inconsistency between declared functional and risk profiles and decision making competences. In this connection, it was found out that the Czech afiliates in which the foreign parent company is involved in transfer pricing set-up incur tax losses. In response to the increasing importance of transfer pricing and international initiative Action Plan BEPS (Base Erosion and Profit Shifting) it can be stated that the approach of the Czech tax authorities has become more intensified and sophisticated. The Czech tax authorities challenge declared and actual functional and risk profile of taxpayers as well as economic substance of realized intercompany transactions. Furthermore, number of transfer pricing audits has increased and become targeted on risky taxpayers such as companies granting investment incentives or incurring tax losses etc. As a result, additional tax assessment due to incorrect transfer pricing significantly increases over recent years.
|
|
| |
|
| |
|
| |
|
|
The role of transnational corporations in developing economies
Botková, Lívia ; Cihelková, Eva (advisor) ; Karpová, Eva (referee)
Bachelor thesis is focused on analysis of inflows and outflows of foreign direct investment (FDI) which are the important source of capital used by transnational corporations (TNCs) to spread their activities worldwide. The objective of the thesis is to analyze the structure of FDI flows by territory and sector/industry in the historical context and the context of the financial crisis of 2007 respectively and the largest TNCs from developed and developing countries. The thesis examines the impact of FDI and TNCs in developing region of the Latin America and the Caribbean which are closely connected with advanced region of North America and therefore show common trends in the development of FDI flows.
|
|
|
Competitive advantage of transnational companies
Smrčková, Michaela ; Jelínková, Eva (advisor) ; Korandová, Jiřina (referee)
Tato práce odpovídá na otázky, proč vznikly nadnárodní společnosti a proč se jim tak daří. Základní teorie vzniku a chování nadnárodních společností v souvislosti se změnami globálního ekonomického prostředí vysvětlují motivy investic v zahraničí. Konkurenční výhody nadnárodních společností oproti národním podnikům spočívají v jejich know-how, možnosti podnikat ve více zemích a v jejich ekonomické síle. Tato práce dále uvádí, jaké jsou možnosti regulace činnosti nadnárodních společností tak, aby byly minimalizovány negativní aspekty a zdůrazněny pozitivní aspekty jejich působení.
|
|
| |
guest ::
