Recently, every main country in the world has implemented transfer pricing system in order to ensure every multinational enterprise would also be able to pay their taxes equitably and reasonably to the countries which they established their multinational enterprises, and has requested the prices of business transaction between every related party have to be set up and adjusted by arm¡¦s length principle. Moreover, in order to follow the initiative of OECD, adopt the current world trend, and avoid the higher inspection risk for our enterprises, Taiwan has established the method of regulation on December twenty- eighth, 2004 by consulting OECD guidelines and tax law of every country in the world, and has started to implement transfer pricing system. The Taiwanese transfer pricing system has integrated in many ways and in many-sided. It also has extended globally. If everyone could cooperate with mutual benefit, the transfer pricing system would be able to maintain the right of native taxation and effectively protect the right of multinational enterprises; hence it is not only a tax system, but art. Therefore, the checking model of transfer pricing system is very different from the case of normal profit-seeking enterprises. The checking model of the current tax authority mainly focuses on their jurisdiction and formal conditions, so it is interesting to see if our tax authority has capability of doing transfer pricing case which emphasizes on the point of taxation principles in substance or not. In addition, because our profit-seeking enterprises are mainly small or middle size corporations, there is a challenge to them to meet their duty and to provide all the requested certificates under the request of the new system, so it is also a point to discuss with. In this research, I tried to establish an evaluation standard by consulting policy estimated theory, and designed a survey which has collected all of recently related books, articles, references, and practiced thoughts in order to have an objective investigation. Also, in the survey, I would like to look into the situations of the following three points after practice of transfer pricing system. First, I would like to find out the thoughts of related interested parties after practice of this policy. Finally, what satisfactions of appropriateness, neutrality, efficiency, responsiveness, and side-effects externalities would be in this policy efficiency analysis? In addition, the collected data were analyzed with Chi-Square test, cross analysis, one-way ANOVA, multiple comparison analysis, and correlation analysis. In my major research findings, transfer pricing system has been known in the certain level by every related interested party. Moreover, this policy is in the high appropriate level and efficient level. However, this policy is in the low neutral level of land tax and other levies, and in the low responsive level. Therefore, there are other side effects in this policy as well, such us: increasing tax misgiving from every enterprise, increasing taxation, and checking cost, etc,. Also, in the result of this research paper, there are twelve suggestions that have collected from the responses of the survey, the problem finding, and some practical difficulties from the study of research institute and some other comments. These twelve suggestions could provide to related government organization as reference material in order to revise the law and advance tax system and tax policy.

The thesis focuses on the transfer pricing questions in the Czech companies. The theoretical part concerns the legislative background, transfer pricing determination methodology and related necessary documentation. The practical part contains the performed questionnaire survey targeted at transfer pricing methods, binding consideration, documentation, and experience with the tax search. A specific manufacturing company is then used to illustrate the manner of transfer pricing determination.

¡§Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's Length Transfer Pricing¡¨ was promulgated in Taiwan on Dec. 28, 2004 which stroke enterprises that set related companies, especially multinational enterprises. In the past, enterprises had been taking advantages of the discrepancy on different countries¡¦ tax system to establish affiliated companies in countries with preferential tax treatment policy or so-called tax paradise district, in order to evade or decrease tax burden. In recent years, with economy globalization and expansion of region integration scope, to respond to the development of industry competition, employing global resources extensively for global arrangement is requisite in promoting competitive power. Therefore, multinational enterprise has been normality day by day. Taxation, a kind of operation cost without additional value, no enterprise doesn¡¦t devote to minimize it for the entire Group. Only to avoid multinational enterprise evading duties of local country in virtue of Transfer Pricing System, each country established transfer pricing assessment system and regulations one after one. To orientate to world trend, maintain fair taxation, and Taiwan¡¦s revenue, Taiwan also speeds up to introduce and complete the system gradually. As a result, this study focuses to explore the new Transfer Pricing System. Exploratory Research is adopted in this study and coordinated with qualitative study method, experienced specialists, enterprise taxation superintendents and tax authority officers who utilize Transfer Pricing System are selected as objectives to perform deep interview, in order to understand the condition of Taiwan¡¦s Transfer Pricing System in real practice. And further generalize and analyze the result obtained from interview, suggestions are made accordingly as follows: (1) Tax authority shall reinforce staff education training and amend legislation defects. (2) Tax authority shall complete and strengthen all kinds of databases and establish way to legally access to database. (3) Tax authority shall consider simplifying transfer pricing report applicable in the scope of enterprise and report content and procedure as well properly. (4) Tax authority shall consider reinforcing the interaction and cooperation with Taiwan¡¦s major countries of foreign trades through taxation forum and so on to avoid double taxation in reality. (5) Enterprise shall strengthen inner staff¡¦s profound understanding towards Transfer Pricing System instead of relying excessively on accountants. (6) Enterprise shall change to adopt the concept of ¡§Most Appropriate Profit, Most Appropriate Taxation.¡¨ When global arrangement is required due to development, to adjust to the application of Transfer Pricing System, function and risk analysis shall serve as basis, to position operation mode and design the most appropriate trade structure in advance, and further refer to proper objectives that can be compared to set transfer price, in order to achieve reasonable profit allocation and make duly adjustment in compliance with changes in reality. (7) Enterprises shall prepare written contract regarding operation mode and trade structure among its related companies, and establish core documents upon the issue of transfer pricing, and further adjust to local transfer pricing report in accordance with the different requirements of countries that branches located. (8) The accountant offices shall reinforce the overall cooperation with enterprises, getting rid of the viewpoint that transfer pricing report is an item of routine annual taxation report to enable specific suggestions be duly offered, and to assist enterprises to make more correct decisions in the respect of global arrangement. (9) Accountant office shall duly raise and make suggestions to tax authority based on the defects of Transfer Pricing Regulation or System that are well known as far as its duties concerned.

In the most cases the market range of transfer pricing is determined from statistical data from previous years. In case of these data the time delay occurs when these data are collected and these data do not reflect if that are collected for period of economical growth or recession. As a result, the final transfer pricing range can become distorted. For this reason it is essential to be familiar with strategies and procedures that can be applied to "clean up" statistical data from the influence of business cycle fluctuations. These strategies and procedures are discussed in this diploma thesis. In the first theoretical chapter are presented transfer pricing issues, set the basic terms, analyzed basic available resources dealing with transfer pricing, defined methods for determining transfer pricing range and identified consequences of the economic crisis in relation to transfer pricing. The second chapter is focused on the selection of the most appropriate method for determining transfer pricing and comparative of both the theoretical and practical basis. The last chapter presents the strategies and procedures that can be used in a comparative analysis, in order to eliminate distortions of the statistical data from the influence of business cycle fluctuations.

This final thesis deals with transfer pricing documentation from the theoretical and practical point of view. The aim of the thesis is to evaluate the settings of transfer prices within fictitious company by using processed documentation The first chapter of the thesis deals with the main principles and approaches to transfer prices to the extent provided by the legal regulations in the Czech Republic. The second chapter deals with the concept of content and composition of the documentation from the point of view of the OECD, EU and CR. In the practical part of the thesis, the intra-group transactions are analyzed in the model documentation, whether they are in accordance with the arm´s length principle.

The result of the global integration of the world economy are globally operating corporations. Multinational enterprises operate in different countries whose economic policies are different from each other. These differences have considerable impact on tax policy. Taxes are the subject of conflicting interests of the international business and tax policy. One of the current objectives of the MNEs is to reduce the total cost in order to achieving competitive advantage in the global market as well as to minimize the global tax liability through its optimization. To achieve these objectives the international tax planning is a widely used means. International tax planning uses tax havens and their favourable tax conditions to divert profits. Minimizing tax liability often leads to tax avoidance or tax evasion. Different legislative adjustments and mutual meeting of local and international legislation gradually uncover gaps and weaknesses enabling reduction and shedding of profits. Consequently, states are deprived of significant tax revenue. One of the most common and most important methods to minimize the tax liability of MNEs is transfer pricing. Transfer prices are to be determined in accordance with the arm's length principle, using comparative analysis and an appropriate method of assessment. Transactions carried out between associated enterprises may be regarded as a risk area which gets to the fore states and tax administrations. The first part of thesis focuses on tax policy in terms of international taxation of income and international tax planning. The second part presents a transfer pricing. The third and last part describes the practices of MNEs in transfer pricing and corresponding initiatives of national and international organizations.

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.

My research concluded by the dissertation thesis focused on transfer pricing in financial management. The aim of this paper was to analyze the use of contracts for cost-sharing, contracts for contributing to the cost and service level agreements in a group of related persons of multinational companies. The work is divided into three logical parts. The first part of my dissertation analyzed the available scientific work and literature. A number of publications deals with the issue but only marginally. I thus drew upon mainly legal texts. I assumed the potential for practical use based on my finding that about 72 % of companies doing business in research and development operate in clusters of related persons. The second part of the paper deals with contracts for cost-sharing and cost contribution agreements. The basic problem of both agreements is reasonable estimation of the expected benefits. I suggested a procedure for estimation of benefit sharing among participants and also what indicators to use for measuring. Then I defined the share of costs. I suggested a definition of K.O. criteria for other than the U.S. legislation for incorrectly estimated shares. In this theoretical treatise on the weighted cost of capital I have found that companies that are not part of a group of related persons have a lower WACC. I pointed to the significant impact of agreements on avoidance of double taxation. As an alternative to the above contracts in the Czech Republic I presented a contract of association under the Civil Code. The third part of this work is dedicated to the Service Level Agreement. I conclude that it is necessary in certain ways to measure benefits, as it is a very important factor for the recipient of services. The benefits, however, cannot be measured directly, but through auxiliary variables, when the determining will always be influenced by the applied accounting standards. The second examined aspect was the allocation of costs to the service provider. Here, I conclude that there is no universally correct way. However, essential for these costs are only the actual relevant costs incurred in connection with the provision of intangible assets. Lastly, I focused on the usual profit margin surcharge over the cost provider of intangible assets. I conclude that when setting profit margins in accordance with the arm's length principle one should build on the level of normal returns on the invested assets of the provider.

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.