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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 documentation
Mitriková, Stanislava ; Frýzek, Libor (advisor) ; Bušovský, Ladislav (referee)
This final thesis deals with transfer pricing documentation from the theoretical and practical point of view. The aim of the thesis is to evaluate the settings of transfer prices within fictitious company by using processed documentation The first chapter of the thesis deals with the main principles and approaches to transfer prices to the extent provided by the legal regulations in the Czech Republic. The second chapter deals with the concept of content and composition of the documentation from the point of view of the OECD, EU and CR. In the practical part of the thesis, the intra-group transactions are analyzed in the model documentation, whether they are in accordance with the arm´s length principle.
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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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Establishing the Transfer Price of Royalties
Saňák, Martin ; Solilová,, Veronika (referee) ; Brychta, Karel (advisor)
The Master’s thesis is concerned with establishing the transfer price of royalties. The thesis is divided into four parts. The theoretical part contains definitions of key words using international and domestic law. The analytical part includes a description of methods recommended by OECD and their use for royalties transactions. The practical part describes a methodical procedure for establishing the transfer price of royalties, which is then used in the next part for a model example.
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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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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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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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Fixing an Independent Transfer Pricing
Kapoun, Vítězslav ; Barták, Martin (referee) ; Svirák, Pavel (advisor)
This bachelor’s thesis deals with a problem of the transfer pricing. It is the price of a transaction between the related enterprises. The issue has recently become one of the main topics of financial authorities. The main reason is that the tax liability can be transferred between companies and thus to countries with the lower tax rate. This thesis deals with consecutions of the transfer price on a specific company using five basic techniques offered by the OECD Guidelines for transfer pricing. These consecutions may be used either for the creation of the documentation required by tax authorities or for the request of the binding assessment on pricing.
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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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