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Issues of Transfer Pricing
 Železný, Stanislav ; Jurečka, Jan (advisor) ; Hackl, Zbyněk (referee)
The aim of the thesis is to approach the issues of transfer pricing, both in terms of legislation, and especially from the perspective of maker of Transfer pricing Documentation and from a practical point of view to analyze the most often transaction between related parties. The thesis is divided into four parts. The first part deals with transfer pricing legislation and provides a general overview of publicity available documents and legal regulation related to transfer pricing issues in the Czech Republic. The second part deals with general and practical look at the Documentation that is used as evidence of transfer prices for tax control. The third part describes transfer pricing methods in detail, which are recommended by OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration. The last part analyzes the most often transactions between related parties and provides particular examples from practice experience.
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