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Valuation in accounting and its impact on taxation
Andrýsková, Adéla ; Molín, Jan (advisor) ; Králíček, Vladimír (referee)
The goal of the diploma thesis is to describe problems of accounting valuation and issues connected with prices, which are used for income tax purposes within current valid legislation. The thesis decribes basic valuation principles, characterization and valuation methods of some selected section according to the Czech legislation and IFRS. The thesis compares advantages and disadvantages of some valuation methods and valuation base and their influence on taxes. At the end of the thesis is the issue of transfer pricing or accounting valuation in insolvency.
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Application of transfer pricing methods for reinsurance
Jun, David ; Francírek, František (advisor) ; Finardi, Savina (referee)
The aim of this diploma thesis is to make a model comparability analysis of controlled transactions within the reinsurance of insurers and to recommend appropriate transfer pricing methods based on defined assumptions. The work is divided into three parts. The first part deals with transfer pricing issues, focusing on comparability analysis and recommended transfer pricing methods according to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations formulated by Organization for Economic Co-operation and Development (Guidelines OECD). The second part describes the basic knowledge and routine practice for the area of reinsurance connected to the transfer of insurance risks. The last part combines the first two chapters, i.e. application of transfer pricing methods in the light of the comparability analysis according to the Guidelines OECD for reinsurance of insurers. The application itself is implemented through the model comparability analysis in order to recommend appropriate transfer pricing methods, i.e. in accordance with the arm's length principle.
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Transfer pricing between related parties and its issues
Čech, Prokop ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Transfer pricing between related parties and its issues As the globalization of the world continues, and as the companies are merging into multinational enterprises, the number of transactions between related parties under circumstances that would not be concluded between unrelated parties is rising. The correct application of transfer pricing between related parties ensures that the transactions are concluded as it would have been between unrelated parties. More and more attention is paid to issue of transfer pricing, frequently in connection with tax planning and tax optimization, which is partly misleading. The tax consequences of transfer pricing are nonetheless substantial. The purpose of this thesis is to analyse transfer pricing issues in the Czech Republic in the context of international rules and standards as set by international organizations, mainly Organization for Economic Cooperation and Development (OECD), United Nations (UN) and European Union (EU), primarily from the tax perspective. The thesis is composed of 11 chapters. In first chapters the thesis describes the basics of transfer pricing, the concept of related parties, arm's length principle, transfer pricing methods and transfer pricing documentation. The next chapters are mainly focused on international transfer pricing...
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International double taxation
Topinka, Lukáš ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
- International double taxation The purpose of this thesis is to describe basic terms, history and importance of double taxation agreements and it also describes European law of double taxation. This thesis is composed of five chapters. Chapter one is an introductory part and describes importance of elimination of international double taxation. Following parts describes structure of this thesis, aim of this thesis and used methods. The second chapter deals with basic terms of double taxation, general meaning of double taxation, tax legislation in Czech Republic and EU law concerning taxation. In following parts, it defines the term of double taxation, both intra national and international and its types. The third part describes the methods of elimination of double taxation, exemption and credit. The fourth part of describes limited and unlimited tax liability. The fifth part deals with tax residents and non-residents, the sixth part deals with transfer pricing. The seventh part discusses tax havens. The last, eight, part is concerned with transparent entities. The third chapter analyzes the international double taxation treaties, their history, importance and basic principles. In following parts, it describes types of these agreements, and in the last part, it describes the provisions of model...
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Safe Harbour Concept in Transfer Pricing
Kolář, Michal ; Heřman, Jan (advisor) ; Dvořáček, Jiří (referee) ; Kapoun, Vítězslav (referee)
Tax administrations worldwide provide taxpayers with favour and offer them the opportunity to set up transfer pricing system according to pre-agreed criteria. When taxpayer´s system complies with, a tax administrator does not dispute the transaction. Any predefined arrangement leading to the recognition of transfer pricing system by the tax administrator can be defined as a safe harbour. It was found out during the review process of current sources, that there is no relevant research available focused on assessing the appropriateness of introducing safe harbour system for both businesses and government. At the same time, even the OECD does not work with data that would conclusively prove the impact of transfer pricing regulation on companies´ behaviour. For this reason, a research was conducted in this area with focus on the potential of safe harbour to affect tax contributions of enterprises. Financial data were rendered from Amadeus database. The impact of safe harbour system was observed on the time series development of taxation of particular cluster. Cluster analysis was selected as the most suitable method for grouping companies.
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Methodology for determining transfer prices in the Czech Republic and the the United States
Horák, Štěpán ; Tepperová, Jana (advisor) ; Kostohryz, Jiří (referee)
The aim of this study is to compare the methodology for determining transfer prices in the Czech Republic and the United States. The reason for choosing these countries are different models, which are governed by states. Czech Republic sets transfer prices according to the OECD model. United States of America set transfer prices according to own regulations. The theoretical part is focused on comparing models and approaches to pricing methodologies. The practical part compares the creatin of a Benchmarking study in these two models.
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The world of Post BEPS transfer pricing
Sadilová, Michaela ; Frýzek, Libor (advisor) ; Zídková, Hana (referee)
The aim of this diploma thesis is to analyze impacts of BEPS including Country-by-Country reporting on the business field and on the tax administration. The theoretical part describes the importance of the initiative of BEPS transfer pricing including its the updated package, Action 8-10. Next part describes and compares the actual transfer pricing regulations in the countries of Visegrad 4 and in Germany. The last part of the diploma thesis analyzes the current transfer pricing situations and the cases of multinational corporation such as Google and Starbucks and it is followed by chaptures analyzing possible advantages and disadvantages that will arise from the new statement of CBCR.
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Methods of transfer pricing by multinational enterprises in terms of tax administration
BÖHMOVÁ, Dana
The aim of the thesis is the analysis and evaluation of the application of transfer (transfer) the prices used in transactions of multinational enterprises in terms of tax administration. Generally describe the basic principles of the United people, the principle of the arm, the methods of the determination of the transfer pricing and documentation for transfer prices in accordance with the international rules and standards laid down by the Organization for economic cooperation and development, in accordance with the laws and guidelines of the Czech Republic. Furthermore, this thesis seeks to clarify the specific case studies, which are based on the practice of financial management, and the case-law, the effects of the determination of the transfer pricing methods, comparison of their advantages and disadvantages in establishing transfer prices in the Czech Republic. At the conclusion of the thesis summed up the results and recommend the adoption of more appropriate legislation in each of the areas of transfer pricing in the Czech Republic.
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Transfer pricing nadnárodních společností
Solilová, Veronika
International tax issues already have not been problems of narrow circle of multinational enterprises. The effect of globalization and international business development causes that many small and medium size firms are now engaged in cross-border transactions and have to face international tax issues. One of the important area of international taxes is transfer pricing. Transfer price is a price set by a taxpayer when selling to, buying from, or sharing resources with a related (associated) person. The transactions between these persons should be assessed at their arm's length price in according the arm's length principle (internationally accepted standard) as the price which would have been agreed between unrelated parties in free market conditions. This thesis focuses on the issue of the transfer pricing that multinational enterprises use to move their tax base to the countries with lower or no tax. The aim of this thesis is based on the analysis of transfer pricing regulations in individual EU member states to propose a new approach or any recommendations for the czech tax policy in the field of transfer pricing. In addition the gained practical knowledge applied to selected case studies.
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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.
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