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International Tax Optimization of Associated Enterprises
Šebková, Lenka ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
This diploma thesis is focused on international tax planning and tax optimization of relaties parties. In the first part of the thesis are written theoretical bases, which are important for understanding the whole work. In the analytical parts are stated the factors that are decisive for international tax planning. At the end of the work is presented the process of international tax planning and tax optimization on a specific subject.
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Setting Transfer Prices between Associated Enterprises
Bobková, Michaela ; Mertová, Šárka (referee) ; Kopřiva, Jan (advisor)
The master thesis deals with the issue of transfer price of a controlled transaction between associated enterprises. Part of the master thesis is definition of basic theoretical concepts associated with the issue of transfer pricing with a focus on domestic, international, and European Union law. The master thesis deals with the analysis of case law, whose subject matter is transfer pricing. The theoretical starting points of the thesis are applied to a practical example, which deals with the issue of determining the transfer price for specific controlled transaction between associated enterprises.
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Issues of transfer pricing
Drobová, Barbora ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
ISSUES OF TRANSFER PRICING Transfer pricing is a very discussed topic of recent years, both by tax subjects, tax advisors as well as by tax administrations. This is due to activities of OECD and the European Union in this area, as well as due to increase in number of tax audits focusing on transfer pricing. The key documents are rules issued by OECD in the form of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which is being constantly revised and supplemented, the latest revision being issued in 2017. In the narrower terms, transfer pricing may be defined as prices for transactions between connected (related) parties. In broad terms, transfer pricing may be defined as any and all transactions between connected (related) parties including in particular transfer of goods, providing of services, transfer and other transactions concerning intangibles, cost contribution arrangements and business restructurings, as well as related tax administrations procedures when deciding on tax duty in connection with the transactions performed between the related parties and the transfer pricing documentation. In the first and second part of this thesis I am outlining the historical progress in activities of OECD in the area of transfer pricing since the first report issued...
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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 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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Methodology for Taxation of Loan Interests between Associated Enterprises
Kropáčová, Hana ; Heligrová, Ilona (referee) ; Brychta, Karel (advisor)
Diploma thesis deals with the issue of loan interest taxation between associated enterprises which are Czech residents. The basic theoretical concepts are described in the first part of thesis. The second part is focused on the analysis Czech law connected with interest taxation. The practical part is based on forming methodological tool for associated enterprises. This methodology can help to set the right loan interest rate. There are also practical examples solved in the end of the diploma thesis.
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Aspects of transfer pricing in the Czech Republic
ZÍTKOVÁ, Božena
The aim of this diploma thesis was to outline the issue of transfer pricing, especially under the conditions of the Czech Republic and to elaborate the documentation for specific company carrying out relationships with related parties. The individual methods of assessment of these prices were introduced in the theoretical component. The possible obstacles connected to its usage were described and most important information needed for transfer pricing documentation were summarized. The practical component includes functional analysis of specific company. Furthermore, all the transactions from the year 2015 amongst related parties were identified and described in detail. In relation to the main production activity the method of net range was used for transfer price verification. The Albertina database was used for elaboration of comparative analysis. To verify the profit margin applied by the company for production, it was used the multi-criterion and gradual weight schedule with subsequent application of point method. This thesis revealed defects that have been presented to the representatives of the company's management. It was stated that it is necessary to perform the revision of profit margin because of profit misinterpretation and lower tax payment of corporate income tax. It was clearly demonstrated that the elaboration of transfer pricing documentation is not a useless administrative burden. On the contrary, it is an important base for mapping and analysing inter-company transactions. Correctly elaborated documentation can be used also a negotiation argument with related parties that are usually in a stronger negotiating position or in dealing with financial administration regarding tax inspection.
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Methodology for Setting a Transfer Price between Associated Enterprises
Trögnerová, Martina ; Pecinová, Jana (referee) ; Brychta, Karel (advisor)
Master thesis deals with the issue of international taxation of transfer prices between related parties. Diploma thesis defines the basic theoretical concepts of transfer pricing with a focus on international and domestic law. The analytical part of the thesis is devoted to the analysis of the case law, the subject of which is transfer pricing. The practical part is based on acquired knowledge to elaborate a methodological tool to transfer pricing. The present findings are applied to a model example.
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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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