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.

Made available in DSpace on 2016-04-26T20:27:12Z (GMT). No. of bitstreams: 1 Thiago Buschinelli Sorrentino.pdf: 3995173 bytes, checksum: bd95b32c746e3b64c8723cdce5cd1d48 (MD5) Previous issue date: 2008-05-06 / This paper examines the judicial review of how tax liability is ascribed to non-taxpayers, upon the Brazil Supreme Court point of view (Supremo Tribunal Federal). Studies, at first, the role of language, logic and Systems Theory as tools which will be used throughout the investigation. Then, rebuilds the syntactic and dynamic structures of the norms that ascribe tax liability. Searches for the constitutional and non-constitutional (National Tax Code) parameters of control. Emphasizes proportionality, reasonableness and the role of general taxation norms within the system. Scrutinizes some of the instruments available to the Brazil Supreme Court (the ação direta de inconstitucionalidade, the recurso extraordinário and the reclamação constitucional). At last, reckons scenarios in order to test some of the conclusions / Esta dissertação de mestrado examina o controle da atribuição de responsabilidade tributária, tomando por parâmetro os instrumentos disponíveis ao Supremo Tribunal Federal. Estuda, inicialmente, o papel da linguagem, da lógica e da Teoria dos Sistemas na formação do quadro. Reconstrói, então, as estruturas sintáticas e dinâmicas das normas de responsabilidade tributária. Procura pelos parâmetros de controle, constitucionais e infraconstitucionais (Código Tributário Nacional). Em especial, dá ênfase à proporcionalidade e a razoabilidade e ao papel das normas gerais em matéria tributária. Escrutiniza alguns dos instrumentos disponíveis ao Supremo Tribunal Federal para o controle da responsabilidade tributária (a ação direta de inconstitucionalidade, o recurso extraordinário e a reclamação constitucional). Por fim, elege cenários para testar alguns pontos das conclusões

The main aim of the thesis is to analyse the national reverse charge in the building industry with a focus on the effect on the selected provider. However, the aim of this study is not only to outline an influence and effect on the business sphere, but make such a methodical basis, which would improve awareness not only in the business sphere but also in the general public. In the theoretical part, important terms are defined and a fundamental theory with a focus on the national reverse charge in the building industry is introduced. In the practical part, the actual application of this system is described in the form of the common opinions and principles, analysis assessing the influence of this system on cash flow, requisitions, tax liability and other factors. The end of this study is created by gathered results and findings of the effect on the selected business partner.

The aim of this theses is analysis of accounting`s conditions and links to tax law, the needs and requirements of accounting in civil associations. For the implementation of the chosen problem into practice was selected civic association OS Stavba ČR. The work focuses on legislative conditions in areas of tax, i.e.. income tax, value added tax, road-traffic tax, real estate tax and gift, inheritance and real estate-tranfer tax. Each tax was analyzed in three views to make them well-arranged: view of the law, the accounting and the practice. The most attention in the practical part of this work is paid to the corporate income tax. Because legislation governing this tax is the most complicated and is therefore placed emphasis on requirements to process background papers and is the most different for organisations involved in the non-profit activities.

The goal is to become familiar with deferred tax concept - explain the nature and bring this accounting term near on a few selected areas. The thesis deals with two different accounting frameworks, Czech legislation and transnational concept in form of International Financial Reporting Standards with the motive to try to explain true nature of deferred tax and to conclude which of the accounting system sufficiently regulates this area so, that it could reflect all important differences with tax system and leads to fair distribution of profits among owners. In other words, not to awarded disposable earnings to those who do not belong solely because of differences between taxes and accounting. Thus, in a situation where these differences did not exist, the belonging amount of allocation of the profit would be else. The thesis is complemented with descriptive examples and illustrations created from real financial statements of two chosen companies. Representative of the Czech framework is Skanska a.s., and for a framework of IFRS the company Unipetrol a.s. The thesis concludes that a more elaborate treatment of deferred tax includes International Financial Reporting Standards, and therefore the financial statements prepared under them provide truer view of an analyzed company to user.

This thesis deals with the real content of legal acts and its evaluation, identification and demonstration by the tax administrator. The aim is to determine which legal institutes are used in the tax administrator's control. Also if it uses the institute of the real content of legal acts and if it uses the correct way according to analysis of Czech law. The first part sets out the legal act, the second part sets out the interpretation of legal acts. The forms of the minimalization of the tax liability is set out in the third part, the greatest emphasis is on tax avoidance and tax evasion. The last part analyzes the most important law cases where the tax administrator argued one of the institutes simulated legal act, dissimulated legal act, evasion of the law, law abuse or tax avoidance by another method.

The diploma thesis focuses on tax administration in the Czech Republic and in Slovakia. It deals with the comparison of procedural law of tax administration, compares the principles enshrined in the relevant laws and marginally deals with the principles of good administration. It also compares chosen taxes obligations, which the taxpayer has to comply with towards tax authorities. The thesis also contains recommended solutions for simulated problem situations.