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National Repository of Grey Literature 2 records found  Search took 0.01 seconds. 
Stanovení převodní ceny pro manažerské poplatky
 Jakubcová, Veronika
This Bachelor’s thesis deals with determining transfer pricing approach in the area of management fees - one of the more controversial parts that are often controlled by tax administrations during tax audits. In the theoretical summary, transfer pricing legislation based on OECD Transfer Pricing Guidelines is examined, as well as related legal measures. It also mentions the issue of management fees as a part of low value-adding services and in connection with their subsequent proving to the tax administration. The practical part focuses on application of transfer pricing approach in the area of management fees for selected entities. It takes account of principles and methods for determining transfer prices in order to be determined according to the arm’s length principle. Within the discussion, the selected entities are advised on how to set appropriate method and approach for determining transfer pricing for management fees so the arm’s length principle is fulfilled and simultaneously the companies are burdened with as low administration as possible.
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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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