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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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Direct Investments and Their Impact on the Economy of the Country (Chosen Aspects)
Doležalová, Michaela ; Jiránková, Martina (advisor) ; Machytka, Daniel (referee)
This bachelor thesis deals with foreign direct investments. The first chapter describes foreign direct investment in general, explains the basic concepts and evolution of their flows in recent years. The second part concentrates on chosen aspects, the impact of foreign direct investments on employment and transfer pricing. The last part of this work is focused on United Kingdom and on flows of direct investments into this country and from this country abroad. The aim of this thesis is to analyze the impact of foreign direct investments on the economy in general and then on one chosen country -- United Kingdom of Great Britain and Northern Ireland.
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Aspects of taxation when entering foreign markets
Berková, Hana ; Černohlávková, Eva (advisor) ; Marková, Michaela (referee)
This diploma thesis analyzes several aspects of taxation when entering a foreign market. The first chapter explains the difference between nominal and effective tax rates and tax burden regulation by enterprises during the current debt crisis. The second chapter deals with double taxation agreements and methods that eliminate double taxation. The third chapter describes the rules of transfer pricing and advance pricing agreements. The last chapter focuses on tax incentives and risks of taxation, especially tax avoidance, tax evasion and the negative attitude of developed countries against tax havens.
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Aplication of transfer pricing in common companies
Kmoch, Daniel ; Francírek, František (advisor) ; Vančurová, Alena (referee)
This final work is trying to evaluate the administrative demands coming from the legal obligation of creating the documentation about the documentation about the transfer prices. In theoretical part autor is talking about the legal requirements for the mandatory documentation about the transfer pricing. In practical part autor is proposing the example of the mandatory documentation of transfer pricing form to existing company and is trying to reply to from what sources are this information coming and if it is about to create a new documents or to use the existing documentation. The conclusion of the work is to evaluate the final administrative demands coming from the obligation to setup the system of transfer pricing.
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Issues of Transfer Pricing
Železný, Stanislav ; Jurečka, Jan (advisor) ; Hackl, Zbyněk (referee)
The aim of the thesis is to approach the issues of transfer pricing, both in terms of legislation, and especially from the perspective of maker of Transfer pricing Documentation and from a practical point of view to analyze the most often transaction between related parties. The thesis is divided into four parts. The first part deals with transfer pricing legislation and provides a general overview of publicity available documents and legal regulation related to transfer pricing issues in the Czech Republic. The second part deals with general and practical look at the Documentation that is used as evidence of transfer prices for tax control. The third part describes transfer pricing methods in detail, which are recommended by OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration. The last part analyzes the most often transactions between related parties and provides particular examples from practice experience.
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