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Transfer Pricing Documentation for a Manufacturing Company
Půčková, Zuzana ; Solilová,, Veronika (referee) ; Brychta, Karel (advisor)
The diploma thesis focuses on the creation of transfer pricing documentation for a company acting as a contract manufacturer with the aim of creating an instrument that will make it easier for the taxpayer to bear the burden of proof. The theoretical part of the thesis defines the basic conceptual apparatus together with the basic principles and legal regulation of transfer pricing. The second part deals with the compilation of a detailed framework for the creation of transfer pricing documentation. The last part of the thesis is devoted to the creation of documentation using the created instructions in the analytical part.
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Tax Deductibility of Loan Interests
Kučera, Vladimír ; Motl, Lubomír (referee) ; Brychta, Karel (advisor)
This thesis deals with the issue of tax deductibility of interest on loans and borrowings from corporate income tax perspective. It consists of an analysis and systematization of the rules influencing the tax deductibility of interest expenses. The result of the thesis is a recommended procedure for capital companies to determine the value of their tax-deductible interest expenses and thus contribute to the correct determination of their tax liability. The proposed methodological approach is verified using a model example.
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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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Methodology for Taxation of Loan Interests between Associated Enterprises
Kropáčová, Hana ; Heligrová, Ilona (referee) ; Brychta, Karel (advisor)
Diploma thesis deals with the issue of loan interest taxation between associated enterprises which are Czech residents. The basic theoretical concepts are described in the first part of thesis. The second part is focused on the analysis Czech law connected with interest taxation. The practical part is based on forming methodological tool for associated enterprises. This methodology can help to set the right loan interest rate. There are also practical examples solved in the end of the diploma thesis.
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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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International Tax Optimization of Associated Enterprises
Šebková, Lenka ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
This diploma thesis is focused on international tax planning and tax optimization of relaties parties. In the first part of the thesis are written theoretical bases, which are important for understanding the whole work. In the analytical parts are stated the factors that are decisive for international tax planning. At the end of the work is presented the process of international tax planning and tax optimization on a specific subject.
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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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