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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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Influence of the European Union activities against aggressive tax planning on enabling tax optimization by member states of the EU
Nováková, Markéta ; Šlosarčík, Ivo (advisor) ; Weiss, Tomáš (referee)
Jurisdictions around the world currently compete to attract mobile capital of multinational companies by providing them the most favourable tax conditions. Some EU member states actively participate in tax competition. Over the past decade, the European Commission has successfully enacted a number of measures aimed at preventing multinational companies from implementing aggressive tax planning schemes. These measures aim to establish fair conditions for competitors on the internal market and to meet the demand of the public and of the international community for suppression of aggressive tax planning. The theoretical background of the thesis derives from the field of Law and Economics, specifically by using the concept of transaction costs and means of Economic analysis of criminality. This thesis aims to answer the question of whether the new EU legislation leaves room for the member states to continue in allowing multinational companies to optimize taxes in the ways targeted by the EU measures. The thesis consists of two case studies, which evaluate the impact of the rules on known tax optimization schemes. The first one analyses the impact of state aid proceedings on tax rulings and the second one analyses the influence of the controlled foreign company rule on harmful IP boxes. The objective...
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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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The lawful application of transfer pricing in business profession
Maděrová, Petra ; Francírek, František (advisor) ; Václavková, Jarmila (referee)
The diploma paper was focused on analysis of the tools -- it means documentation of transfer pricing and advance pricing arrangement leading to the higher tax bond of tax subject, for example: in the case of tax control. The main benefit of this diploma paper consists of analysis of primary data. These data were obtained from the questionnaire as well as from the interviews oriented mainly on tax control which I had led with 2 multinational companies. The questionnaire, which I had done by myself, was sent to 46 multinational companies which their business platforms are located also in the Czech Rep. The most valuable written sources from which some data for my diploma paper were taken is the real documentation of transfer pricing done for the request of advance pricing arrangement as well as the decision of tax administrator in the same case according to the § 38nc Law N. 586/1992 Sb., about income tax. Just the character of the data guarantees the practical application of this diploma paper. I hope according to my diploma paper to be successful in notice of absence in the basic instruments of transfer pricing from point of the multinational companies view which could lead to the adjustment by competent authorities. This adjustment could consequently improve the cooperation between tax subjects and tax authorities.
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Advance Pricing Agreements in The Czech Republic and chosen countries
Vítková, Klára ; Francírek, František (advisor) ; Jelínek, Michal (referee)
This diploma thesis operates with advance pricing agreements. In the Czech Republic, advance pricing agreements were implemented in the form of binding rulings in the year 2006. The goal of the thesis was to analyze and compare binding rulings in the Czech Republic and advance pricing agreements implemented in the countries chosen, which were Germany, Slovakia and Poland, with the theoretical concept of advance pricing agreements as stated in OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
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Transfer pricing and binding rulings
Austerlitzová, Eliška ; Francírek, František (advisor) ; Roháček, Michal (referee)
Setting of transfer price, which is in line with arm's length principle and also with other legislature obligations, is currently with respect of limited experiences with such problematics very actual topic espetially with regard to possible impact. Institution of Billing Rulings of determination of transfer price is a newly established tool leading to legal confidence of tax payers and desireable step forward in Czech legislature. Evaluation of operation and usefulness of this tool is the main goal of my diploma thesis. Tax legisature includes also other editorial obligations of tax authority. Theire description is another objective of my thesis. Analysis of transfer pricing problematics is necessary for understandig the topic and therefore is a partial goal of my thesis. The full picture of transfer pricing Billing Rulings problematics with its aspects analysed on theoretical level is completed with practical example of application for Billing Rulings. The analysis of legislature lead to formulation of suggestions leading to better functioning of this institution.
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