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The Specifics of Financial Management of Holdings Companies
Ficbauer, David ; Kočenda, Evžen (referee) ; Král, Bohumil (referee) ; Zinecker, Marek (referee) ; Režňáková, Mária (advisor)
The main purpose of the thesis is to explore the specifics of the financial management of holdings companies in the Czech Republic with an emphasis on the area of financial management. However, the author assumes that persistent reasons for holding creation is using of synergy effects consisting mainly of centralized management of cash flows to minimize the cost of capital and minimizing the risk of an individual investor who actively makes managerial functions in view guarantees of individual companies. It was found the lack of a comprehensive and systematic approach for a qualitative research. A total of 15 holding companies was use for the qualitative research. The outcome gives many answers concerning the specifics of the financial management of the holdings companies. It seems guarantee and minimizing cost of capital are key points. The synergistic effect of the holding companies can be used when transferring financial means between companies holding. The impact of the transfer of available financial means was simulated for holding No. 13. It was clearly shown to decrease WACC at one of the companies within the holding.
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The issue of transfer pricing in the Czech Republic
Budilová, Michaela ; Bokšová, Jiřina (advisor) ; Randáková, Monika (referee)
The thesis focuses on the transfer pricing questions in the Czech companies. The theoretical part concerns the legislative background, transfer pricing determination methodology and related necessary documentation. The practical part contains the performed questionnaire survey targeted at transfer pricing methods, binding consideration, documentation, and experience with the tax search. A specific manufacturing company is then used to illustrate the manner of transfer pricing determination.
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Tax Evasion and Transfer Pricing
Košťáková, Eliška ; Vítek, Leoš (advisor) ; Zídková, Hana (referee)
The aim of the diploma thesis is to answer the question of where is the line between tax evasion, tax avoidance and tax fraud. Furthermore to characterize methods of measurement tax evasion and introduced actions against tax evasion and tax avoidance at the national and international level. This aim is achieved through analytical and synthetic methods used from the first to third chapter of the diploma thesis. The main goal of diploma thesis is to use external sources of information to determining transfer pricing methods in small economic models. To achieve this goal is at first step explain the Arm's length principle, comparative analysis and subsequently introduced each transfer pricing method. The attention is also paid to assessment of each transfer pricing method with using analytical, synthetic and comparative methods.
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Návrh modelu vybudování Centra sdílených služeb
Vlček, Jiří
VLČEK, Jiří. Model of shared service centre set up. Brno, 2013. Diploma thesis. Mendel university Brno, Faculty of Business and Economics. The subject of the diploma thesis is to propose model of shared service centre set up. Diploma thesis is using analysis, application and modification of management techniques and application of primary data, gathered from multinational companies from various sectors. Final model is composed from 5 phases, including economical point of view.
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Transfer pricing in specific agreements for MNE´s financial management
Brabenec, Tomáš ; Marek, Petr (advisor) ; Krabec, Tomáš (referee) ; Kiesewetter, Zbyněk (referee)
My research concluded by the dissertation thesis focused on transfer pricing in financial management. The aim of this paper was to analyze the use of contracts for cost-sharing, contracts for contributing to the cost and service level agreements in a group of related persons of multinational companies. The work is divided into three logical parts. The first part of my dissertation analyzed the available scientific work and literature. A number of publications deals with the issue but only marginally. I thus drew upon mainly legal texts. I assumed the potential for practical use based on my finding that about 72 % of companies doing business in research and development operate in clusters of related persons. The second part of the paper deals with contracts for cost-sharing and cost contribution agreements. The basic problem of both agreements is reasonable estimation of the expected benefits. I suggested a procedure for estimation of benefit sharing among participants and also what indicators to use for measuring. Then I defined the share of costs. I suggested a definition of K.O. criteria for other than the U.S. legislation for incorrectly estimated shares. In this theoretical treatise on the weighted cost of capital I have found that companies that are not part of a group of related persons have a lower WACC. I pointed to the significant impact of agreements on avoidance of double taxation. As an alternative to the above contracts in the Czech Republic I presented a contract of association under the Civil Code. The third part of this work is dedicated to the Service Level Agreement. I conclude that it is necessary in certain ways to measure benefits, as it is a very important factor for the recipient of services. The benefits, however, cannot be measured directly, but through auxiliary variables, when the determining will always be influenced by the applied accounting standards. The second examined aspect was the allocation of costs to the service provider. Here, I conclude that there is no universally correct way. However, essential for these costs are only the actual relevant costs incurred in connection with the provision of intangible assets. Lastly, I focused on the usual profit margin surcharge over the cost provider of intangible assets. I conclude that when setting profit margins in accordance with the arm's length principle one should build on the level of normal returns on the invested assets of the provider.
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Effect of transfer pricing regulation on permanent estabishment taxation
Jelínek, Michal ; Vančurová, Alena (advisor) ; Izák, Vratislav (referee) ; Vostatek, Jaroslav (referee)
This thesis deals with taxation of permanent establishments and effect of transfer pricing regulation on method of attribution taxable profit to permanent establishments. Firstly, the thesis describes reasons for creation of permanent establishments and analyses how international and local legislation approaches to taxation of their profits. It also examines methods of attribution taxable profit to permanent establishments. Finally, the thesis analyses whether it is possible to use publically available data for determining tax base of "dependent agent" permanent establishment. For this purposes the following methods were used: regression analysis, cluster analysis and logistic regression analysis.
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Double Taxation Treaties and their Influence on Business Activity
Tuláčková, Anna ; Černohlávková, Eva (advisor) ; Smrčková, Michaela (referee)
The thesis is focused on international double taxation and its implications for international business activity. At first, it focuses on double taxation definition, the reasons of its occurrence and its impacts. The next part deals with bilateral double taxation treaties and their principles, including a comparison of Model conventions developed by the OECD and the UN. The last chapter focuses on the areas of transnational corporations activity that are most impacted by tax matters, such as the form of their presence in the foreign market, transfer pricing and international labour hire. The basic principles of international tax planning are explained as well.
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Tax administrative cost of permament establishment
Peroutka, Vojtěch ; Vančurová, Alena (advisor) ; Pšurná, Pavla (referee)
In this dissertation, I describe various types of permanent establishments and other structures through which company may run its business abroad. I calculate and compare tax administrative costs incurred in connection with running such foreign business. Further, I apply this theory on a company that carries on business through a permanent establishment abroad.
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Tax Havens and Its Impact on Economic Growth
McClellan, Collin ; Taušer, Josef (advisor) ; Žamberský, Pavel (referee)
This thesis focuses on the effects tax havens have on both developed and developing countries. The work is presented in four chapters. The first chapter builds a framework of the subject by focusing on tax havens and the issues they create. A brief history of tax havens is discussed and essential statistics are presented. The second chapter discusses the effects tax havens have on developing countries. The link between transfer pricing and tax havens is also analyzed. The third chapter identifies the effects tax havens have on developed countries and its role in the financial crisis. The last chapter explores the current fight against tax havens and their likely impact in the future.
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