National Repository of Grey Literature 2 records found  Search took 0.01 seconds. 
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.
Application of transfer pricing methods for reinsurance
Jun, David ; Francírek, František (advisor) ; Finardi, Savina (referee)
The aim of this diploma thesis is to make a model comparability analysis of controlled transactions within the reinsurance of insurers and to recommend appropriate transfer pricing methods based on defined assumptions. The work is divided into three parts. The first part deals with transfer pricing issues, focusing on comparability analysis and recommended transfer pricing methods according to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations formulated by Organization for Economic Co-operation and Development (Guidelines OECD). The second part describes the basic knowledge and routine practice for the area of reinsurance connected to the transfer of insurance risks. The last part combines the first two chapters, i.e. application of transfer pricing methods in the light of the comparability analysis according to the Guidelines OECD for reinsurance of insurers. The application itself is implemented through the model comparability analysis in order to recommend appropriate transfer pricing methods, i.e. in accordance with the arm's length principle.

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