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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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