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Daňové aspekty soudních sporů v oblasti převodních cen
Volný, Karel
The aim of this thesis is to deduce the consequences of the tax aspects of transfer prices to the taxpayer based on the analysis of selected lawsuits in the area of transfer pricing and case law in this area issued by the Supreme Administrative Court of the Czech Republic (or the EU Court of Justice). The literature review describes the basic concepts, relationships and the transfer pricing legislation. My research deals with the analysis of selected lawsuits as well as with derivation of conclusions from analysing these lawsuits which provide the reader with an overall guide - what has been the court in certain field solving, what has been decided and what should the taxpayer and the tax administrator beware of. Conclusion of the case law is related to specific areas of its usage (rent, production, loans) as well as to the common universal principles - for instance allocation of the burden of proof, the importance of expert opinions or the procedure of calculation of prices.
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Transfer Pricing in Accounting and Taxes
Grieslerová, Zuzana ; Jurka, Robert (advisor) ; Dolanská, Darina (referee)
This bachelor's thesis deals with transfer pricing, the method of its assessment and related transfer pricing documentation. The aim is to introduce main principles and methods used when forming transfer prices, specially the arm's length principle; this thesis also defines controlled transactions between associated enterprises and puts related processes into wider legislative framework and methodological directions of the Czech Republic, European Union and Organisation for Economic Co-operation and Development (OECD). Based on thorough knowledge of the theoretical framework the author proposed transfer pricing documentation of a particular company in a way that could be presented to tax administration both when demonstrating tax obligation and seeking the method approval.
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Transfer pricing documentation
Aubrechtová, Kamila ; Jurečka, Jan (advisor) ; Kačírková, Eliška (referee)
This thesis deals with the issue of transfer pricing, current legislation and methods with emphasis on the creation of transfer pricing documentation. The importance of documentation is mainly to show that prices in transactions between related parties do not differ from the prices agreed between independent parties. The thesis is divided into two main parts, theoretical and practical. The first chapter of this part deals with the definition of the concept of transfer pricing. The second chapter describes the current legislation of transfer pricing, both from the perspective of international regulation, but also in terms of the requirements in the Czech Republic. The following chapters are dedicated to the definition of arm's length principle and methods that can be used in the creation of transfer pricing. The following describes the meaning and way of creating transfer pricing documentation. The practical part deals with creating transfer pricing documentation with application to a particular company in order to verify compliance with the arm's length principle.
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Strategies for determinig transfer prices in period of economical crisis
Skrbková, Lucie ; Francírek, František (advisor) ; Jakoubek, Jiří (referee)
In the most cases the market range of transfer pricing is determined from statistical data from previous years. In case of these data the time delay occurs when these data are collected and these data do not reflect if that are collected for period of economical growth or recession. As a result, the final transfer pricing range can become distorted. For this reason it is essential to be familiar with strategies and procedures that can be applied to "clean up" statistical data from the influence of business cycle fluctuations. These strategies and procedures are discussed in this diploma thesis. In the first theoretical chapter are presented transfer pricing issues, set the basic terms, analyzed basic available resources dealing with transfer pricing, defined methods for determining transfer pricing range and identified consequences of the economic crisis in relation to transfer pricing. The second chapter is focused on the selection of the most appropriate method for determining transfer pricing and comparative of both the theoretical and practical basis. The last chapter presents the strategies and procedures that can be used in a comparative analysis, in order to eliminate distortions of the statistical data from the influence of business cycle fluctuations.
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Transfer pricing documentation
Kocánková, Zuzana ; Buus, Tomáš (advisor) ; Brabenec, Tomáš (referee)
This thesis deals with transfer pricing, namely the documentation. It tries to map the legislative standards and procedures of transfer pricing documentation that could be applied in the Czech Republic. The main objective of this thesis is a compilation of documentation for a specific company in the Czech Republic in accordance with those procedures. The thesis contains three main chapters. The first section mainly covers the basic theoretical concepts and actual legislation regarding transfer pricing. This is the minimum necessary for initiation into the issue. The second chapter deals specifically with the theoretical process of creating documentation. The final, third part of the thesis includes the application of the theory to a specific company.
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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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