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Setting a Transfer Price between Associated Enterprises
Štorová, Nina ; Havířová, Barbora (referee) ; Brychta, Karel (advisor)
This master´s thesis deals with setting a transfer price of controlled transaction between associated enterprises. The goal is to choose the appropriate method for setting transfer prices for controlled transaction of selected associated enterprises and to compare the set transfer prices with prearranged transfer prices stated in the contract between selected associated enterprises. The thesis contains the theoretical basis and legal regulations for transfer prices, possible solutions to the problem of the setting transfer price, procedure for determining transfer price and recommendations for companies on the subject. The final part of the thesis reviews findings from the practical part and offers arising from the reviewed findings.
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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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Transfer pricing documentation
Mitriková, Stanislava ; Frýzek, Libor (advisor) ; Bušovský, Ladislav (referee)
This final thesis deals with transfer pricing documentation from the theoretical and practical point of view. The aim of the thesis is to evaluate the settings of transfer prices within fictitious company by using processed documentation The first chapter of the thesis deals with the main principles and approaches to transfer prices to the extent provided by the legal regulations in the Czech Republic. The second chapter deals with the concept of content and composition of the documentation from the point of view of the OECD, EU and CR. In the practical part of the thesis, the intra-group transactions are analyzed in the model documentation, whether they are in accordance with the arm´s length principle.
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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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Setting a Transfer Price between Associated Enterprises
Štorová, Nina ; Havířová, Barbora (referee) ; Brychta, Karel (advisor)
This master´s thesis deals with setting a transfer price of controlled transaction between associated enterprises. The goal is to choose the appropriate method for setting transfer prices for controlled transaction of selected associated enterprises and to compare the set transfer prices with prearranged transfer prices stated in the contract between selected associated enterprises. The thesis contains the theoretical basis and legal regulations for transfer prices, possible solutions to the problem of the setting transfer price, procedure for determining transfer price and recommendations for companies on the subject. The final part of the thesis reviews findings from the practical part and offers arising from the reviewed findings.
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The issue of transfer pricing in the Czech Republic
Budilová, Michaela ; Bokšová, Jiřina (advisor) ; Randáková, Monika (referee)
The thesis focuses on the transfer pricing questions in the Czech companies. The theoretical part concerns the legislative background, transfer pricing determination methodology and related necessary documentation. The practical part contains the performed questionnaire survey targeted at transfer pricing methods, binding consideration, documentation, and experience with the tax search. A specific manufacturing company is then used to illustrate the manner of transfer pricing determination.
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Transfer pricing in specific agreements for MNE´s financial management
Brabenec, Tomáš ; Marek, Petr (advisor) ; Krabec, Tomáš (referee) ; Kiesewetter, Zbyněk (referee)
My research concluded by the dissertation thesis focused on transfer pricing in financial management. The aim of this paper was to analyze the use of contracts for cost-sharing, contracts for contributing to the cost and service level agreements in a group of related persons of multinational companies. The work is divided into three logical parts. The first part of my dissertation analyzed the available scientific work and literature. A number of publications deals with the issue but only marginally. I thus drew upon mainly legal texts. I assumed the potential for practical use based on my finding that about 72 % of companies doing business in research and development operate in clusters of related persons. The second part of the paper deals with contracts for cost-sharing and cost contribution agreements. The basic problem of both agreements is reasonable estimation of the expected benefits. I suggested a procedure for estimation of benefit sharing among participants and also what indicators to use for measuring. Then I defined the share of costs. I suggested a definition of K.O. criteria for other than the U.S. legislation for incorrectly estimated shares. In this theoretical treatise on the weighted cost of capital I have found that companies that are not part of a group of related persons have a lower WACC. I pointed to the significant impact of agreements on avoidance of double taxation. As an alternative to the above contracts in the Czech Republic I presented a contract of association under the Civil Code. The third part of this work is dedicated to the Service Level Agreement. I conclude that it is necessary in certain ways to measure benefits, as it is a very important factor for the recipient of services. The benefits, however, cannot be measured directly, but through auxiliary variables, when the determining will always be influenced by the applied accounting standards. The second examined aspect was the allocation of costs to the service provider. Here, I conclude that there is no universally correct way. However, essential for these costs are only the actual relevant costs incurred in connection with the provision of intangible assets. Lastly, I focused on the usual profit margin surcharge over the cost provider of intangible assets. I conclude that when setting profit margins in accordance with the arm's length principle one should build on the level of normal returns on the invested assets of the provider.
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Strategies for determinig transfer prices in period of economical crisis
Skrbková, Lucie ; Francírek, František (advisor) ; Jakoubek, Jiří (referee)
In the most cases the market range of transfer pricing is determined from statistical data from previous years. In case of these data the time delay occurs when these data are collected and these data do not reflect if that are collected for period of economical growth or recession. As a result, the final transfer pricing range can become distorted. For this reason it is essential to be familiar with strategies and procedures that can be applied to "clean up" statistical data from the influence of business cycle fluctuations. These strategies and procedures are discussed in this diploma thesis. In the first theoretical chapter are presented transfer pricing issues, set the basic terms, analyzed basic available resources dealing with transfer pricing, defined methods for determining transfer pricing range and identified consequences of the economic crisis in relation to transfer pricing. The second chapter is focused on the selection of the most appropriate method for determining transfer pricing and comparative of both the theoretical and practical basis. The last chapter presents the strategies and procedures that can be used in a comparative analysis, in order to eliminate distortions of the statistical data from the influence of business cycle fluctuations.
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Tax aspects of business between associated enterprises -- stipulation of the method for distributive enterprise
Kuncová, Jana ; Jelínek, Michal (advisor)
This thesis "Tax aspects of business between associated enterprises -- stipulation of the method for distributive enterprise" considering associated enterprises and transfer pricing, as they are defined by documents of European Union, OECD and Czech Republic. It compares the definitions of associated enterprises and the arm's length principle according to OECD and the law of Czech Republic. It gives the list of methods transfer pricing which are used when making the prices for transactions between associated enterprises. These methods are divided into traditional and profitable - it depends on the kind of transaction. In the last part of this thesis on the basis of the analysis of these documents I recommend the optimal method for transfer pricing for a concrete enterprise.
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