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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.
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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.
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Setting Transfer Price for Management Fees
Pevná, Daniela ; Málka, Ondřej (referee) ; Brychta, Karel (advisor)
The master´s thesis deals with the issue of setting transfer prices for management services between associated enterprises. The thesis contains a theoretical definition of basic concepts and analysis of legislation. The content of the analytical part of the thesis is the analysis of the current state and analysis of case law. The theoretical background is applied in the practical part to a model example which is determined by setting transfer price for management services between internal associated enterprises.
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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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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.
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Setting Transfer Price for Management Fees
Pevná, Daniela ; Málka, Ondřej (referee) ; Brychta, Karel (advisor)
The master´s thesis deals with the issue of setting transfer prices for management services between associated enterprises. The thesis contains a theoretical definition of basic concepts and analysis of legislation. The content of the analytical part of the thesis is the analysis of the current state and analysis of case law. The theoretical background is applied in the practical part to a model example which is determined by setting transfer price for management services between internal associated enterprises.
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Bezpečné přístavy v oblasti transférových cen
Baránková, Barbora
The subject of the diploma thesis is to establish safe harbours for management fees. Safe harbours as a transfer pricing scheme are based on the Transfer Prices Guide-lines for Multinational Enterprises and Tax Authorities from 2017. This scheme entails simplification for businesses, which should reduce the burden on businesses in the production of transfer pricing. The work mainly focuses on setting safe harbours for a fairly controversial area of management fees and the safe harbours are based on setting the usual market margins for selected management services.
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Transferové ceny a jejich využití jako metody minimalizace daňové povinnosti
Paroulek, Alex
The thesis is focused on the issue of transfer pricing and their usage as a method of tax liability minimization. The aim of this thesis is to describe how usable are transfer prices for achieving minimization of tax liability and to determine how intensively they are supervised by tax authorities. The application part is concentrated on the description of the transfer prices with the focus on the law side of this issue. There are analysed the case laws from European Court of Justice and Supreme Administrative Court of the Czech Republic in the second part of this thesis, where taxpayers achieved minimization of their tax liability thanks to transfer prices.
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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.
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