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Tax Aspects of Transfer Pricing
Gottvaldová, Hana ; Svirák, Pavel (referee) ; Svirák, Pavel (advisor)
Master thesis deals with setting a transfer price of controlled transaction between associated enterprises and its impacts on the tax liability of the tax subject. Master thesis defines basic theoretical concepts, legal regulations of transfer pricing, description of methods for setting transfer prices and procedure for determination these prices. Based of this knowledge, an example of the method for setting transfer prices for selected controlled transaction is elaborated. In final part of this thesis, the results are evaluated and recommendations for optimizing the tax liability of the company are determined by modifying the example.
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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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Determination of Transfer Prices in OEZ Group
Toman, Petr ; Šťerba, Jan (referee) ; Kocmanová, Alena (advisor)
The theme of my thesis „Determination of Transfer Prices in OEZ group“ is determination the way of creation transfer prices for business iterrelations between affined companies. Work is focused on theoretic knowledge from areas of transfer prices whose pillar is „The Arm´s Length Principle“. With it relating tax correlation and required production of documentation for transparence for financing organs. Final recommendation are target to how (in the concrete and also generally) above all on problems resulting from current economic situation. Of binding force recommendation touche above all areas cover binding appreciation about correctness of creation transfer prices.
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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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Tax Aspects of Transfer Pricing
Gottvaldová, Hana ; Svirák, Pavel (referee) ; Svirák, Pavel (advisor)
Master thesis deals with setting a transfer price of controlled transaction between associated enterprises and its impacts on the tax liability of the tax subject. Master thesis defines basic theoretical concepts, legal regulations of transfer pricing, description of methods for setting transfer prices and procedure for determination these prices. Based of this knowledge, an example of the method for setting transfer prices for selected controlled transaction is elaborated. In final part of this thesis, the results are evaluated and recommendations for optimizing the tax liability of the company are determined by modifying the example.
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Financial responsibility management of divisionalized companies
Navrátil, Jakub ; Wagner, Jaroslav (advisor) ; Král, Bohumil (referee)
An opening part of the thesis explains the role of responsibility accounting within overall management control system of a company. Individual chapters are focused on the key specific aspects of businesses with a divisionalized organizational structure. A description of principal characteristics related to this type of an organizational structure is followed by a detailed explanation of various types of responsibility centers. A subsequent chapter deals with bookkeeping aspects of responsibility accounting as well as with transfer prices. A theoretical part is concluded after a comprehensive analysis of a characteristic features related to responsibility centers' financial management on different levels of a corporate's hierarchy. An application part of the thesis is based on an assessment of responsibility accounting environment within a chosen responsibility center inside a real divisionalized corporation.
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Determination of Transfer Prices in OEZ Group
Toman, Petr ; Šťerba, Jan (referee) ; Kocmanová, Alena (advisor)
The theme of my thesis „Determination of Transfer Prices in OEZ group“ is determination the way of creation transfer prices for business iterrelations between affined companies. Work is focused on theoretic knowledge from areas of transfer prices whose pillar is „The Arm´s Length Principle“. With it relating tax correlation and required production of documentation for transparence for financing organs. Final recommendation are target to how (in the concrete and also generally) above all on problems resulting from current economic situation. Of binding force recommendation touche above all areas cover binding appreciation about correctness of creation transfer prices.
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Tax administrative cost of permament establishment
Peroutka, Vojtěch ; Vančurová, Alena (advisor) ; Pšurná, Pavla (referee)
In this dissertation, I describe various types of permanent establishments and other structures through which company may run its business abroad. I calculate and compare tax administrative costs incurred in connection with running such foreign business. Further, I apply this theory on a company that carries on business through a permanent establishment abroad.
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