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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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The Project Proposal for Founding of Non-profit Organisation
Kapoun, Vítězslav ; Senjuková, Miroslava (referee) ; Doskočil, Radek (advisor)
This diploma’s thesis deals with a problem of the project management in connection with the founding of non-profit organizations. The aim of this thesis is to create a project proposal, which would allow founding of a non-profit organization and ensuring its financing. The non-profit organization will be founded in order to arrange the leisure activities of children and youth. During the making of the project proposal the methods which are being used in the project management by the international organization IPMA were used.
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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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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.
|
|
|
The Project Proposal for Founding of Non-profit Organisation
Kapoun, Vítězslav ; Senjuková, Miroslava (referee) ; Doskočil, Radek (advisor)
This diploma’s thesis deals with a problem of the project management in connection with the founding of non-profit organizations. The aim of this thesis is to create a project proposal, which would allow founding of a non-profit organization and ensuring its financing. The non-profit organization will be founded in order to arrange the leisure activities of children and youth. During the making of the project proposal the methods which are being used in the project management by the international organization IPMA were used.
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