|
|
Setting Transfer Prices between Associated Enterprises
Bobková, Michaela ; Mertová, Šárka (referee) ; Kopřiva, Jan (advisor)
The master thesis deals with the issue of transfer price of a controlled transaction between associated enterprises. Part of the master thesis is definition of basic theoretical concepts associated with the issue of transfer pricing with a focus on domestic, international, and European Union law. The master thesis deals with the analysis of case law, whose subject matter is transfer pricing. The theoretical starting points of the thesis are applied to a practical example, which deals with the issue of determining the transfer price for specific controlled transaction between associated enterprises.
|
|
|
Tax Havens and Their Use
Komárková, Renata ; Filipová, Vladimíra (referee) ; Kopřiva, Jan (advisor)
This master thesis deals with the characteristics of tax havens, approach beneficiary companies and way of their use and potential abuse. The first part defines basic terms, which are tax havens are closely linked. The second part is devoted to the characterization chosen tax havens in different areas of model-based taxation example of two types of companies. The third part contains the suggestions and recommendations for setting up a company in a tax haven.
|
|
|
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.
|
|
|
The Specifics of Financial Management of Holdings Companies
Ficbauer, David ; Kočenda, Evžen (referee) ; Král, Bohumil (referee) ; Zinecker, Marek (referee) ; Režňáková, Mária (advisor)
The main purpose of the thesis is to explore the specifics of the financial management of holdings companies in the Czech Republic with an emphasis on the area of financial management. However, the author assumes that persistent reasons for holding creation is using of synergy effects consisting mainly of centralized management of cash flows to minimize the cost of capital and minimizing the risk of an individual investor who actively makes managerial functions in view guarantees of individual companies. It was found the lack of a comprehensive and systematic approach for a qualitative research. A total of 15 holding companies was use for the qualitative research. The outcome gives many answers concerning the specifics of the financial management of the holdings companies. It seems guarantee and minimizing cost of capital are key points. The synergistic effect of the holding companies can be used when transferring financial means between companies holding. The impact of the transfer of available financial means was simulated for holding No. 13. It was clearly shown to decrease WACC at one of the companies within the holding.
|
|
|
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.
|
|
| |
|
|
Creation of Foreign Branch of the Company
Novák, Ladislav ; Sedlář, Roman (referee) ; Koráb, Vojtěch (advisor)
The topic of the thesis is the comprehensive proposal for establishing foreign branch of the company in the Baltics with a distribution network across the countries of the region. The theoretical part is focused on basic information regarding the legal requirements in the countries concerned. Practical part deals with the specific formation of a subsidiary and commissioning.
|
|
|
Cash-pooling z pohledu převodních cen
Podsedníková, Lucie
Podsedníková, L. Cash-pooling from the perspective of transfer prices. Bachelor thesis. Brno: Mendel University in Brno, 2023. The bachelor's thesis deals with the topic of financial transactions within as-sociated entities, specifically the issue of cash-pooling. The thesis contains a theo-retical framework where concepts related to transfer pricing and cash-pooling are explained. The aim of the work is the evaluation and application of the arm’s length principle to the cash-pooling structure with an emphasis on the identifica-tion of risks when determining the arm’s length interest and proposing a solution to eliminate these risks.
|
|
|
Finanční transakce z pohledu transferových cen: cash-pooling
Glajšeková, Veronika
Glajšeková, V. Financial transactions from a transfer pricing perspective: cash pooling. Bachelor thesis. Brno: Mendel University, 2023. The bachelor thesis deals with financial transactions in transfer pricing, with cash pooling as its main focus. The first part of the thesis deals with the theoretical substate of the issue. The aim of the thesis is to evaluate the effects of different cashpooling structures and the creditworthiness of the entities involved on the determination of the usual interest rates granted by the bank for credit/debit balances on the master account of the cash pooling structure.
|
|
|
Bezpečné prístavy v oblasti prevodních cien so zameraním na rozvojové štáty
Molnárová, Lucia
The issue of transfer pricing is currently one of the most significant tax probems, which needs to be confronted by multinational enterprises and tax authorities all over the world. The determination of transfer prices that is based on the application of the arm´s length principle, together with the administration and control of transfer pricing is often complicated, time-consuming and costly process. Especially for developing countries, many of which experience difficulties with col-lection data and their analysis due to the lack of information regarding comaparable transactions. For this reason, developing countries should consider using the safe harbour concept, at least for smaller taxpayers or in a case of less complicated transactions. This thesis focuses on proposal of safe harbour for selected develo-ping countries in Asia.
|
guest ::
