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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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Transfer pricing: Transactional Net Margin Method and its practical application
Šebestová, Anna ; Buus, Tomáš (advisor) ; Fritzsche, Vít (referee)
The diploma thesis is devoted to the transfer pricing, particularly focusing on one of the transfer pricing methods: the transactional net margin method. In the theoretical part, the thesis deals with the transfer pricing legislation and demonstrates examples of how the profit transfer may occur. Further the thesis describes the transfer pricing methods and its use, mainly focusing on the transactional net margin method and its practical application. It deals with the profit level indicators and the comparability that must be followed when applying this method. In the practical part the thesis presents a Czech manufacturing company engaged in transactions with related parties. Using the functional and comparative analysis the compliance with the arm's length principle is determined.
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Thin capitalisation in Czech Republic
Flaška, Ondrej ; Francírek, František (advisor) ; Roun, Vlastimil (referee)
This diploma thesis deals with thin capitalisation rules in the Czech Republic. The main objective is to analyze tax-deductibility of financial costs connected with loans from related parties. Czech Republic has been member of EU since 2004. The EU membership established the responsibility for Czech Republic to approximate national legislation of taxation with EU law, so the second objective of the diploma thesis is to consider how the Czech Republic deals with harmonisation of tax-deductible financial cost connected with loans from related parties.
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Transfer pricing in the case law of the Supreme Administrative Court
Králová, Simona ; Frýzek, Libor (advisor) ; Jelínek, Michal (referee)
Based on the analysis of selected decisions of The Supreme Administrative Court in the area of transfer pricing, this document aims at identifying the general interpretation principles of the law by The Supreme Administrative Court. It also provides taxpayers with guidelines how to interpret the law and act in practice. The work is divided into three parts. The first part introduces legal regulations in the Czech Republic that relate to transfer pricing. In the second part, selected decisions of The Supreme Administrative Court in the area of transfer pricing are analysed. In the third part, the identified principles are formulated.
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Creative accounting with impact on income tax
Kudláčková, Pavla ; Polák, Martin (advisor)
In this thesis I will try to clarify the concept of "creative accounting". I will engage in describing individual techniques that could lead to a wrong statement. Then, I will continue to identify more specific processes that affect the overall management. In conclusion, I work on reasons that lead to practices of creating accounting and also its consequences.
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Transfer pricing and binding rulings
Austerlitzová, Eliška ; Francírek, František (advisor) ; Roháček, Michal (referee)
Setting of transfer price, which is in line with arm's length principle and also with other legislature obligations, is currently with respect of limited experiences with such problematics very actual topic espetially with regard to possible impact. Institution of Billing Rulings of determination of transfer price is a newly established tool leading to legal confidence of tax payers and desireable step forward in Czech legislature. Evaluation of operation and usefulness of this tool is the main goal of my diploma thesis. Tax legisature includes also other editorial obligations of tax authority. Theire description is another objective of my thesis. Analysis of transfer pricing problematics is necessary for understandig the topic and therefore is a partial goal of my thesis. The full picture of transfer pricing Billing Rulings problematics with its aspects analysed on theoretical level is completed with practical example of application for Billing Rulings. The analysis of legislature lead to formulation of suggestions leading to better functioning of this institution.
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Tax and Legal Structure of Tescoma Group
Hasoňová, Martina ; Kříž, Radim (advisor) ; Chára, Petr (referee)
The thesis is focused on holding companies legislation in the Czech Republic and related issue of tax optimization in the international business environment. First aim of this thesis is to map control and influence relations and therefrom arising legal obligations within Tescoma Group. Second aim is to explore Tescoma Group from the point of view of tax optimization and to compare advantages and disadvantages of alternative structures of the group.
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