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Setting a Transfer Price between Associated Enterprises
Štorová, Nina ; Havířová, Barbora (referee) ; Brychta, Karel (advisor)
This master´s thesis deals with setting a transfer price of controlled transaction between associated enterprises. The goal is to choose the appropriate method for setting transfer prices for controlled transaction of selected associated enterprises and to compare the set transfer prices with prearranged transfer prices stated in the contract between selected associated enterprises. The thesis contains the theoretical basis and legal regulations for transfer prices, possible solutions to the problem of the setting transfer price, procedure for determining transfer price and recommendations for companies on the subject. The final part of the thesis reviews findings from the practical part and offers arising from the reviewed findings.
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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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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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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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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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The problematics of transfer pricing in Czech and International tax law
Valeš, Ondřej ; Kotáb, Petr (advisor) ; Kohajda, Michael (referee)
The problematics of transfer pricing in Czech and International tax law Constant globalization leads to the boom of business and property-related companies, which we call multinational. Multinational companies carry out so-called intra-company transactions within their group of companies under different conditions than they would in normal business. We call these transactions dependent, because they are carried out between affiliates, in an environment that is not competitive but related. Transfer pricing issues are usually associated with tax optimization because, with the help of these transactions, multinationals are able to achieve a lower tax burden. Aggressive tax optimization prevents proper transfer pricing for intra-company transactions. Transfer pricing of intra-company transactions is set up properly if they are in line with the arm length's principle, which in its own way attempts to simulate a competitive environment. The aim of this work is to outline the regulation of transfer pricing in Czech and International tax law and to analyse the problems of the regulation. In Czech law, the transfer pricing is mainly regulated in the Income Tax Act and in the non-binding instructions of the Ministry of Finance, which rely heavily on international regulation. At international level, the...
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Transfer pricing
Řehoř, Marek ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Transfer pricing Abstract The thesis focuses on transfer pricing which falls within a scope of international taxation. The aim of the theses is to define transfer pricing, describe transfer pricing rules and to assess these rules. The first part of the theses focuses on international taxation, especially BEPS. Double tax treaties and ATAD directive are further described. The second part of the diploma theses focuses on transfer pricing from international perspective. Transfer prices are prices agreed between associated enterprises. The fundamental concept of transfer pricing is arm's length principle. The prices agreed between associated enterprises should equal to prices which would have been agreed between independent parties. The arm's length principle is included within the double tax treaties. The theses further focuses on OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, especially comparability analysis and transfer pricing methods, which are used for setting up of transfer prices. The third part of the theses focuses on transfer pricing rules from the Czech perspective. The respective rules are included within the Income Taxes Act and legally non-binding guidance, which follow the international rules. The Czech Tax Authorities increase their attention on...
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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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