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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.
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Prediction of bankruptcy by bankruptcy models before the subsequent entry into insolvency in a selected group of related entities
ULRYCHOVÁ, Michaela
This diploma thesis deals with insolvency and prediction of bankruptcy in selected groups of related companies. The main goal is to predict the bankruptcy of individual companies in a group of related companies using selected bankruptcy models. These were used for two groups, one in the field of construction and the other in craft services. A partial goal is to evaluate the financial health of individual companies in the group by using ratios and their subsequent comparison with the results of bankruptcy models. Subsequently, the registered receivables of individual companies in insolvency proceedings will be analysed and the actual date of real company's bankruptcy will be determined. Finally, all results will be summarized, the reliability of individual models and recommendations for each company will be determined. Data for all analysis will be drawn from the financial statements and annual reports of individual companies, as well as from the Commercial and Insolvency Register.
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The problematics of transfer pricing in Czech and International tax law
Valeš, Ondřej ; Kotáb, Petr (advisor) ; Kohajda, Michael (referee)
The problematics of transfer pricing in Czech and International tax law Constant globalization leads to the boom of business and property-related companies, which we call multinational. Multinational companies carry out so-called intra-company transactions within their group of companies under different conditions than they would in normal business. We call these transactions dependent, because they are carried out between affiliates, in an environment that is not competitive but related. Transfer pricing issues are usually associated with tax optimization because, with the help of these transactions, multinationals are able to achieve a lower tax burden. Aggressive tax optimization prevents proper transfer pricing for intra-company transactions. Transfer pricing of intra-company transactions is set up properly if they are in line with the arm length's principle, which in its own way attempts to simulate a competitive environment. The aim of this work is to outline the regulation of transfer pricing in Czech and International tax law and to analyse the problems of the regulation. In Czech law, the transfer pricing is mainly regulated in the Income Tax Act and in the non-binding instructions of the Ministry of Finance, which rely heavily on international regulation. At international level, the...
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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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Setting Transfer Price for Management Fees
Pevná, Daniela ; Málka, Ondřej (referee) ; Brychta, Karel (advisor)
The master´s thesis deals with the issue of setting transfer prices for management services between associated enterprises. The thesis contains a theoretical definition of basic concepts and analysis of legislation. The content of the analytical part of the thesis is the analysis of the current state and analysis of case law. The theoretical background is applied in the practical part to a model example which is determined by setting transfer price for management services between internal associated enterprises.
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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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Návrh efektívného cash managementu podniku prostrednictvom cash poolingu
Vatolík, Adam
The diploma thesis review issues of cash pooling and its application to the company with global presence. It deals with both the advantages and disadvantages of real and notional cash pooling and further focuses on the legal framework of cash pooling in Czech Republic, Germany and the Slovak Republic. The main aim is to bring forward the suitable pooling structures for the needs of the chosen company, evaluate them according to the goals set up by the management and withdraw the optimal solution.
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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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Transferové ceny a jejich využití jako metody minimalizace daňové povinnosti
Paroulek, Alex
The thesis is focused on the issue of transfer pricing and their usage as a method of tax liability minimization. The aim of this thesis is to describe how usable are transfer prices for achieving minimization of tax liability and to determine how intensively they are supervised by tax authorities. The application part is concentrated on the description of the transfer prices with the focus on the law side of this issue. There are analysed the case laws from European Court of Justice and Supreme Administrative Court of the Czech Republic in the second part of this thesis, where taxpayers achieved minimization of their tax liability thanks to transfer prices.
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