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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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Seeding machines: preparation of learning material
KOLÁŘ, Michal
This bachelor work is focused on the Seeders and their issues. The aim of this thesis is the preparation of educational texts for students of agricultural technology. In the first part it is shown the historical development of the seeding machinery, agro-technical requirements to them and also a description of the basic parts, which are the seeders consist. The next part of the thesis is devoted to the most important manufacturers of seeding machines, which are available on the Czech market. At the conclusion šěof the work of these machines compared. The criterion for the comparison is the working width of 6 metres
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Driver for equatorial mount
Kolář, Michal ; Richter, Miloslav (referee) ; Havlíková, Marie (advisor)
Within the bachelor’s thesis a design of the controller for equatorial mount Celestron AstroMaster CG-3 was worked out. It will enable to control the movements of the te- lescope by means of steeping motors and the control unit, according to the requirements of the user.
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Security applications on the Apple iOS platform
Kolář, Michal ; Martinásek, Zdeněk (referee) ; Hajný, Jan (advisor)
This document deals with the security of iOS operating system. It describes applications which ensure the safety of the entire file system and private files of the user. It further describes mechanisms for authentication of the user and for credibility verification of third- party applications. The practical part is devoted to the installation of the development environment Xcode and introduces the reader to its work environment. The practical part is focused to create an application which will implement a security protocol. Also include work with another additional libraries which will be needed to create an application. Output application will be generated QR code with all required values of cryptographic protocol
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Entropic generator of random numbers
Kolář, Michal ; Číž, Radim (referee) ; Burda, Karel (advisor)
This paper is focused on generating random number via entropy generators. There are described sources of entropy on personal computer and described methods of detecting their entropy. There are also described basic operations used for construction and for concept solution this generator under NIST recommendation for personal computer and methods of their testing.
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Detached house
Kolář, Michal ; Kalábová, Tereza (referee) ; Bečkovský, David (advisor)
In this bachelor thesis I am focusing on a project of a detached family house on a site 5017 in a village Radiměř. Proposed category of a flat is 4+1. Family house is designed according to an irregular platform 14,84x8,08m. The house has two floors with a habitable attic, without cellarage. Downstairs there is a space behind a door, technical room, a toilet a storage room, a storage room under the stairway, two-ply stairs, a living room and a kitchen. The family house includes a garage for one car and with enough storage space. Upstairs there is a bathroom, 2 rooms and a bedroom. The house is based on strip foundations made of a simple concrete. Vertical and horizontal frameworks are devised from cellular concrete blocks Ytong. Enclosure wall is insulated by boards Ytong Multipor. The roof is anticlinal with a 40 degrees deflection. The entering side is orientated to the east. The living room is orientated to the south and the west, which makes the place shiny enough and furthermore there is an entrance to the platform. In addition there is also a bachelor seminar thesis on a following topic Insulation and insulation systems.
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Present active market labor policy in Czech republic and its alternatives
Kolář, Michal ; Prachař, Ondřej (advisor) ; Vebrová, Ludmila (referee)
The bachelor thesis examines measurement of dependence between active and passive market labor policy costs and unemployment rate in Czech republic in 2000-2011. In another part bacherol thesis deals with analyses of effectiveness and targeting retraining courses in Czech republic in 2007-2010. Dependence of active and passive market labor policy costs is measured by correlation coefficient. According to results of bachelor thesis increasing active labor market policy costs could reduce unemployment rate. Increase of costs on passive labor market policy could be independent on unemployment rate. Targeting is measured by targeting index. Vulnerable groups of unemployed are less targeted and they are affected by creaming off effect. Efectiveness is measured by gross effects. Gross effects at vulnerable group are below average. It shows us low effectiveness of retraining courses for people who gets high care support by employment agency.
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