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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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Fixing an Independent Transfer Pricing
Kapoun, Vítězslav ; Barták, Martin (referee) ; Svirák, Pavel (advisor)
This bachelor’s thesis deals with a problem of the transfer pricing. It is the price of a transaction between the related enterprises. The issue has recently become one of the main topics of financial authorities. The main reason is that the tax liability can be transferred between companies and thus to countries with the lower tax rate. This thesis deals with consecutions of the transfer price on a specific company using five basic techniques offered by the OECD Guidelines for transfer pricing. These consecutions may be used either for the creation of the documentation required by tax authorities or for the request of the binding assessment on pricing.
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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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Establishing the Transfer Price of Royalties
Saňák, Martin ; Solilová,, Veronika (referee) ; Brychta, Karel (advisor)
The Master’s thesis is concerned with establishing the transfer price of royalties. The thesis is divided into four parts. The theoretical part contains definitions of key words using international and domestic law. The analytical part includes a description of methods recommended by OECD and their use for royalties transactions. The practical part describes a methodical procedure for establishing the transfer price of royalties, which is then used in the next part for a model 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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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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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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