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Methodology for Setting a Transfer Price between Associated Enterprises
Trögnerová, Martina ; Pecinová, Jana (referee) ; Brychta, Karel (advisor)
Master thesis deals with the issue of international taxation of transfer prices between related parties. Diploma thesis defines the basic theoretical concepts of transfer pricing with a focus on international and domestic law. The analytical part of the thesis is devoted to the analysis of the case law, the subject of which is transfer pricing. The practical part is based on acquired knowledge to elaborate a methodological tool to transfer pricing. The present findings are applied to a model example.
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Some aspects tax control
Peláková, Andrea ; Boháč, Radim (advisor) ; Marková, Hana (referee)
My dissertation deals with some aspects which are connected with tax kontrol. The main point of my paper is to give a detailed description od selected aspects nad to compare thme according to an old and a new version of legal acjustment. An introductory chapter pays attention to defining tax control. Following chapters deals with the opening of tax kontrol, repeated tax kontrol, periods for tax setting, kontrol report and means of protection dutiny the tax control. My own practical experience with tax kontrol is written about in the last chapter.
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Tax control
Skálová, Eva ; Boháč, Radim (advisor) ; Kohajda, Michael (referee)
The subject of this diploma thesis is the tax control which can be classified to the financial law sector. The aim of the thesis is a basic description and introduction to the tax control. During writing my diploma thesis I used legal regulation from several legal branches to clarify the tax control and I considered them in the (mutual) context related to the topic of the tax control. For the comprehensive solution of the tax control issue it was also necessary to apply related judicial decisions and literature. I described the findings concerning the tax control in the diploma thesis by using the description and subsequently I deduced certain conclusions by using the deduction method. I also dealt with ambiguous issues of the tax control which I tried to clarify and take legal opinion on them and imply possible de lege ferendae changes. The diploma thesis consists of the introduction where the subject and the aim of the diploma thesis are introduced. The subject of the following chapters is the general part of the tax control, particular stages of the tax control, consequences of the tax control and means of rights protection. The last part of the diploma thesis devotes to the conclusion, including a summary of the diploma thesis and proposed de lege ferendae changes. The above mentioned diploma...
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Some aspects tax control
Peláková, Andrea ; Boháč, Radim (advisor) ; Marková, Hana (referee)
My dissertation deals with some aspects which are connected with tax kontrol. The main point of my paper is to give a detailed description od selected aspects nad to compare thme according to an old and a new version of legal acjustment. An introductory chapter pays attention to defining tax control. Following chapters deals with the opening of tax kontrol, repeated tax kontrol, periods for tax setting, kontrol report and means of protection dutiny the tax control. My own practical experience with tax kontrol is written about in the last chapter.
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Control systems in financial law
Veselá, Lenka ; Marková, Hana (advisor) ; Boháč, Radim (referee) ; Papoušková, Zdenka (referee)
CONTROL SYSTEMS IN FINANCIAL LAW RESUME JUDr. et Mgr. Lenka Veselá The proposed thesis deals with control systems, focusing on financial law. The theme of this work was chosen with regard to the current situation in society, taking into account the global economic crisis. Monitoring is an inseparable part of every well -functioning state therefore it is important to keep eye on this very rigorously and also address a further specifies control. Control is dynamically evolving topic that is still actual and cannot be found any area of human life, where it is not needed. As applied in a wide range of areas for this work was chosen just a part of law closer focusing on the area of financial law. Financial control, as presented in this work, is a broad definition of procedures for the control authorities in the individual sub-sectors of financial law. It can be defined as financial control in public administration, as well as a tax inspection, customs control, foreign exchange control in management. Financial control is also applied in the field of monetary law, fee law, banking law, etc. We could trace a system of financial control in all the various sub- sectors of the financial law. For this reason was chosen the view of the issue as to the control systems in financial law. The system is the set of all...
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Methodology for Setting a Transfer Price between Associated Enterprises
Trögnerová, Martina ; Pecinová, Jana (referee) ; Brychta, Karel (advisor)
Master thesis deals with the issue of international taxation of transfer prices between related parties. Diploma thesis defines the basic theoretical concepts of transfer pricing with a focus on international and domestic law. The analytical part of the thesis is devoted to the analysis of the case law, the subject of which is transfer pricing. The practical part is based on acquired knowledge to elaborate a methodological tool to transfer pricing. The present findings are applied to a model example.
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Application of selected practices of creative accounting in connection with tax reduction of an individual entrepreneur
Rajdl, Jan ; Molín, Jan (advisor) ; Králíček, Vladimír (referee)
Creative accounting is often connected with larger companies that try to overestimate their reported profit by using creative accounting. It is usually performed in order to attract potential investors or to gain a higher credit from the financial institutions. The aim of this bachelor thesis is the effort to point out that using of creative accounting cannot be connected only with overestimation of the financial statements by companies and consequently to outline the alternative interpretation and application of creative accounting by other subjects. These accounting entities are represented in the thesis by a Czech individual entrepreneur through whom the specific examples how to use creative accounting in order to underestimate reported profit are shown. Such efforts will result among other things in a lower tax payment flowing to the state budget.
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Tax control in accounting and legal context
Vrbová, Lenka ; Jirásková, Simona (advisor) ; Molín, Jan (referee)
The bachelor thesis gives a handle for the purpose of a tax control issues unconventionally, by combining the two perspectives, law and accounting. It defines the basic concepts, which are tax administration, tax administrator, tax control. Tax control is characterized from the perspective of law, it's initiation, progress and termination. It also deals with the rights and obligations of the taxpayer and the tax administrator, which are imposed to them for the purpose of tax control by the Tax Procedure Code. The work focuses on selected accounting areas that tax administrator most scans. Ordering these selected areas within the chapter respects the process of transformation of the accounting profit before tax at the corporate tax base. At the end there are connected the selected findings from the published financial controls Czech tax administration.
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The lawful application of transfer pricing in business profession
Maděrová, Petra ; Francírek, František (advisor) ; Václavková, Jarmila (referee)
The diploma paper was focused on analysis of the tools -- it means documentation of transfer pricing and advance pricing arrangement leading to the higher tax bond of tax subject, for example: in the case of tax control. The main benefit of this diploma paper consists of analysis of primary data. These data were obtained from the questionnaire as well as from the interviews oriented mainly on tax control which I had led with 2 multinational companies. The questionnaire, which I had done by myself, was sent to 46 multinational companies which their business platforms are located also in the Czech Rep. The most valuable written sources from which some data for my diploma paper were taken is the real documentation of transfer pricing done for the request of advance pricing arrangement as well as the decision of tax administrator in the same case according to the § 38nc Law N. 586/1992 Sb., about income tax. Just the character of the data guarantees the practical application of this diploma paper. I hope according to my diploma paper to be successful in notice of absence in the basic instruments of transfer pricing from point of the multinational companies view which could lead to the adjustment by competent authorities. This adjustment could consequently improve the cooperation between tax subjects and tax authorities.
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