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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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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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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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The Transfer Pricing in Selected Business Enterprise
KUPKOVÁ, Kristýna
This diploma thesis deals with the issue of transfer pricing. Based on the performed functional, risk and comparative analysis, it proposes recommendations to the company leading to the elimination or mitigation of identified risks. The selected enterprise and its group are characterized by performing a functional and risk analysis, it is characterized and on this basis the transactions taking place within the group are analyzed. These transactions are compared with the market environment of comparable companies. On the basis of the calculated market profit range, conclusions are made about compliance with the market distance principle. Part of the overall analysis is also an analysis of the comparison of margins for products sold within the group, which is also compared with the margins charged to unrelated parties to explain the sales strategy of the selected company. According to the information obtained from the analysis of the company's financial environment, the main risks to the company resulting from the market environment and poorly set transfer pricing policy are outlined. After carrying out the given procedure, it was found that the company complies with the principle of market distance in the examined years, however, the business policy setting requires the introduction of strict control over the future development of the transfer price.
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The problematics of transfer pricing in Czech and International tax law
Valeš, Ondřej ; Kotáb, Petr (advisor) ; Kohajda, Michael (referee)
The problematics of transfer pricing in Czech and International tax law Constant globalization leads to the boom of business and property-related companies, which we call multinational. Multinational companies carry out so-called intra-company transactions within their group of companies under different conditions than they would in normal business. We call these transactions dependent, because they are carried out between affiliates, in an environment that is not competitive but related. Transfer pricing issues are usually associated with tax optimization because, with the help of these transactions, multinationals are able to achieve a lower tax burden. Aggressive tax optimization prevents proper transfer pricing for intra-company transactions. Transfer pricing of intra-company transactions is set up properly if they are in line with the arm length's principle, which in its own way attempts to simulate a competitive environment. The aim of this work is to outline the regulation of transfer pricing in Czech and International tax law and to analyse the problems of the regulation. In Czech law, the transfer pricing is mainly regulated in the Income Tax Act and in the non-binding instructions of the Ministry of Finance, which rely heavily on international regulation. At international level, the...
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Analysis of transfer mispricing of commodity exports in African countries
Zachar, Martin ; Janský, Petr (advisor) ; Kracík, Jiří (referee)
Governments around the world are burdened by what is estimated to be a $160 billion annual tax loss stemming from transfer mispricing. Developing countries may be even more susceptible to this phenomenon due to their lax reporting and regulatory standards. However, research done to date on transfer mispricing with regards to developing countries is very limited. This paper investigates commodity transactions between selected African countries and the world for 2008-2009, looking for pricing anomalies in both absolute terms and in relation to global mispricing averages. The data was examined using linear regression models, volume-based analysis and case study analyses. While the former two did not find convincing evidence of substantial price distortions, the latter uncovered several anomalies that may point to mispricing. These results point to the fact that transfer mispricing occurring in developing countries is in line with that of the rest of the world.
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Transfer pricing
Řehoř, Marek ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Transfer pricing Abstract The thesis focuses on transfer pricing which falls within a scope of international taxation. The aim of the theses is to define transfer pricing, describe transfer pricing rules and to assess these rules. The first part of the theses focuses on international taxation, especially BEPS. Double tax treaties and ATAD directive are further described. The second part of the diploma theses focuses on transfer pricing from international perspective. Transfer prices are prices agreed between associated enterprises. The fundamental concept of transfer pricing is arm's length principle. The prices agreed between associated enterprises should equal to prices which would have been agreed between independent parties. The arm's length principle is included within the double tax treaties. The theses further focuses on OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, especially comparability analysis and transfer pricing methods, which are used for setting up of transfer prices. The third part of the theses focuses on transfer pricing rules from the Czech perspective. The respective rules are included within the Income Taxes Act and legally non-binding guidance, which follow the international rules. The Czech Tax Authorities increase their attention on...
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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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Issues of Transfer Pricing
Radikovská, Daniela ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
ISSUES OF TRANSFER PRICING Transfer pricing has been often-discussed topic in recent years which is unlikely to change in the upcoming years. Given the great importance of transfer pricing in international tax planning, as well as in so called aggressive tax planning, it is a priority for states to set transfer pricing rules based on the arm's length principle in such a way that untaxed profits are not transferred from the jurisdictions where it was generated. Although this is a tax issue concerning the direct taxation, it shall be regulated at least in a coordinated manner by most countries in the world, as the international overlap is the greatest danger to state treasuries. From the perspective of taxpayers, it is often very difficult to meet all obligations regarding the setting of transfer pricing pursuant the arm's length principle, but it can be pointed out that a sufficiently clearly specified rules may be in favor of the taxpayers, because unjustified price manipulation between the related parties may cause some distortion of the functioning of the market. The main purpose of this thesis is to provide a comprehensive overview of transfer pricing issues from the perspective of Czech legislation, especially the Income Tax Act and instructions issued by the Ministry of Finance and the...
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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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