|
| |
|
| |
|
|
Transfer Pricing Documentation for a Manufacturing Company
Půčková, Zuzana ; Solilová,, Veronika (referee) ; Brychta, Karel (advisor)
The diploma thesis focuses on the creation of transfer pricing documentation for a company acting as a contract manufacturer with the aim of creating an instrument that will make it easier for the taxpayer to bear the burden of proof. The theoretical part of the thesis defines the basic conceptual apparatus together with the basic principles and legal regulation of transfer pricing. The second part deals with the compilation of a detailed framework for the creation of transfer pricing documentation. The last part of the thesis is devoted to the creation of documentation using the created instructions in the analytical part.
|
|
|
Cross-border aspects of corporate taxation
Laouici, Said ; Kotáb, Petr (advisor) ; Tuláček, Michal (referee)
- 1 - Cross-border aspects of corporate taxation Abstract This thesis addresses the key challenges, institutions, and current challenges in the cross- border taxation of concerns, which are better known as multinational companies. Multinational companies are business associations that must achieve the quality to be described as concerns, which are the focus of this thesis. The essential aspects in the cross-border taxation of a concern are the existence of double taxation or non-taxation, the transfer pricing and, finally, the new institutes that are aimed at reacting to the most recent and unsolved issues in this area. These are still numerous, but the efforts of countries and multinational organisations to tackle them are very strong. Specifically, this thesis deals with the essential instruments in the field of international taxation, such as double taxation treaties, transfer pricing, which can be described as traditional institutes, but also new institutes in the field of international taxation, which are BEPS action plans (Pillar I and Pillar II), MLI, EU directives, which compete with the basic and new instruments. The BEPS Action Plans and their impact are continuously reflected in each chapter of this thesis. The thesis also deals with tax competition, coordination, and harmonisation relationships...
|
|
|
Tax Aspects of Transfer Pricing
Gottvaldová, Hana ; Svirák, Pavel (referee) ; Svirák, Pavel (advisor)
Master thesis deals with setting a transfer price of controlled transaction between associated enterprises and its impacts on the tax liability of the tax subject. Master thesis defines basic theoretical concepts, legal regulations of transfer pricing, description of methods for setting transfer prices and procedure for determination these prices. Based of this knowledge, an example of the method for setting transfer prices for selected controlled transaction is elaborated. In final part of this thesis, the results are evaluated and recommendations for optimizing the tax liability of the company are determined by modifying the example.
|
|
|
Tax Havens and Their Use
Komárková, Renata ; Filipová, Vladimíra (referee) ; Kopřiva, Jan (advisor)
This master thesis deals with the characteristics of tax havens, approach beneficiary companies and way of their use and potential abuse. The first part defines basic terms, which are tax havens are closely linked. The second part is devoted to the characterization chosen tax havens in different areas of model-based taxation example of two types of companies. The third part contains the suggestions and recommendations for setting up a company in a tax haven.
|
|
| |
|
|
Cash-pooling z pohledu převodních cen
Podsedníková, Lucie
Podsedníková, L. Cash-pooling from the perspective of transfer prices. Bachelor thesis. Brno: Mendel University in Brno, 2023. The bachelor's thesis deals with the topic of financial transactions within as-sociated entities, specifically the issue of cash-pooling. The thesis contains a theo-retical framework where concepts related to transfer pricing and cash-pooling are explained. The aim of the work is the evaluation and application of the arm’s length principle to the cash-pooling structure with an emphasis on the identifica-tion of risks when determining the arm’s length interest and proposing a solution to eliminate these risks.
|
|
|
Bezpečné prístavy v oblasti prevodních cien so zameraním na rozvojové štáty
Molnárová, Lucia
The issue of transfer pricing is currently one of the most significant tax probems, which needs to be confronted by multinational enterprises and tax authorities all over the world. The determination of transfer prices that is based on the application of the arm´s length principle, together with the administration and control of transfer pricing is often complicated, time-consuming and costly process. Especially for developing countries, many of which experience difficulties with col-lection data and their analysis due to the lack of information regarding comaparable transactions. For this reason, developing countries should consider using the safe harbour concept, at least for smaller taxpayers or in a case of less complicated transactions. This thesis focuses on proposal of safe harbour for selected develo-ping countries in Asia.
|
|
|
Transfer prices: meaning and definition from constitutional law perspective
Hájek, Jan ; Marková, Hana (advisor) ; Mrkývka, Petr (referee) ; Sejkora, Tomáš (referee)
140 Transfer prices: meaning and definition from constitutional law perspective Abstract The thesis deals with the problem of the definition of transfer prices in the substantive tax law, which in general terms it puts in connection with the constitutional requirements arising from the theory of law and normative formation. Thus, the basic grounds for the regulation of transfer pricing in Act No. 586/1992 Coll., on Income Taxes and the OECD Model Double Tax Convention as primary sources of law, legislative definition of this area in domestic and international tax law are defined. These are further elaborated into the detailed level of the methodology of determining the transfer price, which follows from the Instruction of the General Tax Directorate D - 34 and the OECD Transfer Pricing Guideline, and are also subjected to a critical examination in terms of their legal bindingness, position in the legal system, but also from the perspective of the rule of law maxim in the sense of the clarity of the law and its predictability. On the basis of the submitted argumentation, it is concluded that none of the above-mentioned documents defining the procedure by which the transfer price is to be determined is a binding source of law a limine and will always constitute only a non-binding instruction or guide to its...
|
guest ::
