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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 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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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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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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Selected Tax Aspects of International Business
Tichá, Dominika ; Černohlávková, Eva (advisor) ; Marková, Michaela (referee)
The result of the global integration of the world economy are globally operating corporations. Multinational enterprises operate in different countries whose economic policies are different from each other. These differences have considerable impact on tax policy. Taxes are the subject of conflicting interests of the international business and tax policy. One of the current objectives of the MNEs is to reduce the total cost in order to achieving competitive advantage in the global market as well as to minimize the global tax liability through its optimization. To achieve these objectives the international tax planning is a widely used means. International tax planning uses tax havens and their favourable tax conditions to divert profits. Minimizing tax liability often leads to tax avoidance or tax evasion. Different legislative adjustments and mutual meeting of local and international legislation gradually uncover gaps and weaknesses enabling reduction and shedding of profits. Consequently, states are deprived of significant tax revenue. One of the most common and most important methods to minimize the tax liability of MNEs is transfer pricing. Transfer prices are to be determined in accordance with the arm's length principle, using comparative analysis and an appropriate method of assessment. Transactions carried out between associated enterprises may be regarded as a risk area which gets to the fore states and tax administrations. The first part of thesis focuses on tax policy in terms of international taxation of income and international tax planning. The second part presents a transfer pricing. The third and last part describes the practices of MNEs in transfer pricing and corresponding initiatives of national and international organizations.
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Determination of transfer pricing using alternative methods
Kubešová, Lucie ; Francírek, František (advisor) ; Málek, Jiří (referee)
The focus of this thesis is alternative methods used to determine transfer pricing in practice, mainly in the environment where there is a lack of available comparable information in the market. The paper is divided into four chapters. The first lists basic terminology, available relevant legislation and briefly outlines particular methods of determining a transfer pricing as recommended by OECD directives and the use of those. The second chapter focuses mostly on identifying of an interval for transfer pricing acceptable for tax authorities under a sale of an enterprise or its part. The third chapter mentions further alternative methods for which the underlying asset for determining of transfer price are financial derivatives. The last chapter discusses the results of carried out analyses and presents recommendations to using alternative methods. The thesis contents are supported by a designed computer program, which is a key element for using the alternative methods in practice.
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Transfer prices in banking
Bučko, Michal ; Marek, Petr (advisor) ; Brabenec, Tomáš (referee)
This thesis elaborates possible approach to determination of the optimal transfer price for tax purposes as for ordinary transactions undertaken in a banking group. The first part deals with the theoretical approach of the determination of transfer prices while describing the regulation of transfer prices according to the OECD. The intention of the second part is to evaluate the possibility of setting the optimal transfer price for tax purposes in the banking group. Common transactions were identified within a banking group in order to achieve this objective. Subsequently, the generally used methodology and approach to setting of transfer prices for tax purposes in commercial banks was in the thesis characterized. At the end of the second part, a possible approach was compiled to the possibility of setting the optimal transfer price for tax purposes through a theoretical model.
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