National Repository of Grey Literature 49 records found  1 - 10nextend  jump to record: Search took 0.00 seconds. 
Bezpečné prístavy v oblasti prevodních cien so zameraním na rozvojové štáty
Molnárová, Lucia
The issue of transfer pricing is currently one of the most significant tax probems, which needs to be confronted by multinational enterprises and tax authorities all over the world. The determination of transfer prices that is based on the application of the arm´s length principle, together with the administration and control of transfer pricing is often complicated, time-consuming and costly process. Especially for developing countries, many of which experience difficulties with col-lection data and their analysis due to the lack of information regarding comaparable transactions. For this reason, developing countries should consider using the safe harbour concept, at least for smaller taxpayers or in a case of less complicated transactions. This thesis focuses on proposal of safe harbour for selected develo-ping countries in Asia.
Transfer prices: meaning and definition from constitutional law perspective
Hájek, Jan ; Marková, Hana (advisor) ; Mrkývka, Petr (referee) ; Sejkora, Tomáš (referee)
140 Transfer prices: meaning and definition from constitutional law perspective Abstract The thesis deals with the problem of the definition of transfer prices in the substantive tax law, which in general terms it puts in connection with the constitutional requirements arising from the theory of law and normative formation. Thus, the basic grounds for the regulation of transfer pricing in Act No. 586/1992 Coll., on Income Taxes and the OECD Model Double Tax Convention as primary sources of law, legislative definition of this area in domestic and international tax law are defined. These are further elaborated into the detailed level of the methodology of determining the transfer price, which follows from the Instruction of the General Tax Directorate D - 34 and the OECD Transfer Pricing Guideline, and are also subjected to a critical examination in terms of their legal bindingness, position in the legal system, but also from the perspective of the rule of law maxim in the sense of the clarity of the law and its predictability. On the basis of the submitted argumentation, it is concluded that none of the above-mentioned documents defining the procedure by which the transfer price is to be determined is a binding source of law a limine and will always constitute only a non-binding instruction or guide to its...
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...
International double taxation
Topinka, Lukáš ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
- International double taxation The purpose of this thesis is to describe basic terms, history and importance of double taxation agreements and it also describes European law of double taxation. This thesis is composed of five chapters. Chapter one is an introductory part and describes importance of elimination of international double taxation. Following parts describes structure of this thesis, aim of this thesis and used methods. The second chapter deals with basic terms of double taxation, general meaning of double taxation, tax legislation in Czech Republic and EU law concerning taxation. In following parts, it defines the term of double taxation, both intra national and international and its types. The third part describes the methods of elimination of double taxation, exemption and credit. The fourth part of describes limited and unlimited tax liability. The fifth part deals with tax residents and non-residents, the sixth part deals with transfer pricing. The seventh part discusses tax havens. The last, eight, part is concerned with transparent entities. The third chapter analyzes the international double taxation treaties, their history, importance and basic principles. In following parts, it describes types of these agreements, and in the last part, it describes the provisions of model...
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...
Associated Persons and Their Identification Critera as Specified in Case-law of the Czech Administrative Courts
Gabryš, Lukáš ; Kopřiva, Jan (referee) ; Brychta, Karel (advisor)
This bachelor thesis analyses the issue of associated persons in the context of transfer pricing. Each category of these persons is described in more details. The thesis puts forward an enumeration of typical and relatively undispute examples and analyses matters without the absolute consensus among the professional public on their resolutions. Furthermore, in some passages, it considers some aspects related to this topic which haven’t been researched perfectly yet. In total, this bachelor thesis creates much more complete and comprehensive image of the issue.
Issues of Transfer Pricing
Radikovská, Daniela ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
ISSUES OF TRANSFER PRICING Transfer pricing has been often-discussed topic in recent years which is unlikely to change in the upcoming years. Given the great importance of transfer pricing in international tax planning, as well as in so called aggressive tax planning, it is a priority for states to set transfer pricing rules based on the arm's length principle in such a way that untaxed profits are not transferred from the jurisdictions where it was generated. Although this is a tax issue concerning the direct taxation, it shall be regulated at least in a coordinated manner by most countries in the world, as the international overlap is the greatest danger to state treasuries. From the perspective of taxpayers, it is often very difficult to meet all obligations regarding the setting of transfer pricing pursuant the arm's length principle, but it can be pointed out that a sufficiently clearly specified rules may be in favor of the taxpayers, because unjustified price manipulation between the related parties may cause some distortion of the functioning of the market. The main purpose of this thesis is to provide a comprehensive overview of transfer pricing issues from the perspective of Czech legislation, especially the Income Tax Act and instructions issued by the Ministry of Finance and the...
Zjednodušená stanovení převodních cen pro SME
Francová, Jitka
Francová, J. Simplified Transfer Pricing for SME. Diploma thesis. Brno: Mendel University, 2015. In 2013 OECD has reviewed Section E on Safe Harbors in Chapter IV of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities, and offered set of simplification measures that, if implemented, would ease transfer pricing processes for specific transaction or tax payer groups. Main focus of this thesis are possible simplification methods or safe harbors that could be used to ease the administrative burden for SME's and propose recommendations on use of such measures in the Czech Republic.
Transfer pricing and its effect on financial reporting and taxation
Pryma, Kateryna
The diploma thesis deals with the impact of transfer pricing on financial reporting and taxation for the companies operating under different accounting systems (US GAAP and IFRS). In theoretical part examined various methods of transfer pricing used in the United States, OECD-member countries and main considerations taken into account for the determination of arm's length range and transfer prices. In practical part shown the differences in approaches to transfer pricing in the USA and countries of pan-European area considering the connection with financial reporting and taxation.
Dopady převodních cen na základ daně z příjmů korporací
Saidi, Veronika
The diploma thesis is focused on transfer pricing, which the multinational companies use to transfer profits in order to minimize the tax within the group. The goal is to quantify the impacts of using individual methods on corporate income tax using the Amadeus database and identify possible loopholes that corporations use for tax planning.

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