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Transfer pricing
Řehoř, Marek ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Transfer pricing Abstract The thesis focuses on transfer pricing which falls within a scope of international taxation. The aim of the theses is to define transfer pricing, describe transfer pricing rules and to assess these rules. The first part of the theses focuses on international taxation, especially BEPS. Double tax treaties and ATAD directive are further described. The second part of the diploma theses focuses on transfer pricing from international perspective. Transfer prices are prices agreed between associated enterprises. The fundamental concept of transfer pricing is arm's length principle. The prices agreed between associated enterprises should equal to prices which would have been agreed between independent parties. The arm's length principle is included within the double tax treaties. The theses further focuses on OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, especially comparability analysis and transfer pricing methods, which are used for setting up of transfer prices. The third part of the theses focuses on transfer pricing rules from the Czech perspective. The respective rules are included within the Income Taxes Act and legally non-binding guidance, which follow the international rules. The Czech Tax Authorities increase their attention on...
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Issues of Transfer Pricing
Radikovská, Daniela ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
ISSUES OF TRANSFER PRICING Transfer pricing has been often-discussed topic in recent years which is unlikely to change in the upcoming years. Given the great importance of transfer pricing in international tax planning, as well as in so called aggressive tax planning, it is a priority for states to set transfer pricing rules based on the arm's length principle in such a way that untaxed profits are not transferred from the jurisdictions where it was generated. Although this is a tax issue concerning the direct taxation, it shall be regulated at least in a coordinated manner by most countries in the world, as the international overlap is the greatest danger to state treasuries. From the perspective of taxpayers, it is often very difficult to meet all obligations regarding the setting of transfer pricing pursuant the arm's length principle, but it can be pointed out that a sufficiently clearly specified rules may be in favor of the taxpayers, because unjustified price manipulation between the related parties may cause some distortion of the functioning of the market. The main purpose of this thesis is to provide a comprehensive overview of transfer pricing issues from the perspective of Czech legislation, especially the Income Tax Act and instructions issued by the Ministry of Finance and the...
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Zjednodušená stanovení převodních cen pro SME
Francová, Jitka
Francová, J. Simplified Transfer Pricing for SME. Diploma thesis. Brno: Mendel University, 2015. In 2013 OECD has reviewed Section E on Safe Harbors in Chapter IV of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities, and offered set of simplification measures that, if implemented, would ease transfer pricing processes for specific transaction or tax payer groups. Main focus of this thesis are possible simplification methods or safe harbors that could be used to ease the administrative burden for SME's and propose recommendations on use of such measures in the Czech Republic.
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Transfer pricing and its effect on financial reporting and taxation
Pryma, Kateryna
The diploma thesis deals with the impact of transfer pricing on financial reporting and taxation for the companies operating under different accounting systems (US GAAP and IFRS). In theoretical part examined various methods of transfer pricing used in the United States, OECD-member countries and main considerations taken into account for the determination of arm's length range and transfer prices. In practical part shown the differences in approaches to transfer pricing in the USA and countries of pan-European area considering the connection with financial reporting and taxation.
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Dopady převodních cen na základ daně z příjmů korporací
Saidi, Veronika
The diploma thesis is focused on transfer pricing, which the multinational companies use to transfer profits in order to minimize the tax within the group. The goal is to quantify the impacts of using individual methods on corporate income tax using the Amadeus database and identify possible loopholes that corporations use for tax planning.
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Stanovení převodní ceny pro manažerské poplatky
Jakubcová, Veronika
This Bachelor’s thesis deals with determining transfer pricing approach in the area of management fees - one of the more controversial parts that are often controlled by tax administrations during tax audits. In the theoretical summary, transfer pricing legislation based on OECD Transfer Pricing Guidelines is examined, as well as related legal measures. It also mentions the issue of management fees as a part of low value-adding services and in connection with their subsequent proving to the tax administration. The practical part focuses on application of transfer pricing approach in the area of management fees for selected entities. It takes account of principles and methods for determining transfer prices in order to be determined according to the arm’s length principle. Within the discussion, the selected entities are advised on how to set appropriate method and approach for determining transfer pricing for management fees so the arm’s length principle is fulfilled and simultaneously the companies are burdened with as low administration as possible.
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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.
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The analysis oh the legal regulation of transfer pricing in connection with the implementation of ATAD
Zedníková, Kateřina ; Boháč, Radim (advisor) ; Sejkora, Tomáš (referee)
The analysis of the legal regulation of transfer pricing in connection with the implementation of ATAD Abstract This diploma thesis deals with the topic of legal regulation of transfer prices. Considering the gradual globalization and the increasing number of multinational enterprises, transfer pricing is a very extensively discussed tax-related topic. It has become even more topical with the implementation of a new Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market. Transposition period for the majority of regulations presented in the directive is scheduled to 31 December 2018. The aim of the present thesis is to characterize the current state of legal regulations of transfer pricing in the Czech Republic as well as related supranational regulations. Within the context of the former and the latter, the thesis analyzes the options of the implementation of the Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market. Also, the thesis delineates and describes the approach of the Ministry of Finance of the Czech Republic, including an assumed financial impact of the implementation of individual...
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The Application of Trends of Transfer Pricing Adjustments of Selected European Countries in the Czech Republic
Nekovář, Jiří ; Karfíková, Marie (advisor) ; Boháč, Radim (referee) ; Bělohlávek, Alexander (referee)
/ Résumé / Zusammenfassung Transfer pricing is currently a very relevant topic. Tax administrations are focusing on unveiling and penalizing tax evasion and in author's opinion also on prevention and reduction of tax optimization using intragroup transactions with price designed to minimize taxation. The volume of tax base and tax adjustments by tax administrations multiplied in recent years without significant changes in relevant legislation and that raises a question whether this change is not contrary to the principle of legality use of powers conferred by public law. This thesis analyzes reasons for these changes, which are connected to significant increase in number of group cross border transactions. In European context the increase is partially result of intensive economic integration of member states. Second important aspect leading to the relevance of this topic is the intensity public perception of this issue which to large extent eliminates the difference between tax avoidance and illegal tax evasion. The thesis generally focuses on transfer pricing in European context created by the activities of OECD reflected by EU legislation. The analysis shows that the OECD document on the issue are very beneficial instruments and their use is in many cases unified by the EU, which analyzes the...
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