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 aim of this diploma thesis was to outline the issue of transfer pricing, especially under the conditions of the Czech Republic and to elaborate the documentation for specific company carrying out relationships with related parties. The individual methods of assessment of these prices were introduced in the theoretical component. The possible obstacles connected to its usage were described and most important information needed for transfer pricing documentation were summarized. The practical component includes functional analysis of specific company. Furthermore, all the transactions from the year 2015 amongst related parties were identified and described in detail. In relation to the main production activity the method of net range was used for transfer price verification. The Albertina database was used for elaboration of comparative analysis. To verify the profit margin applied by the company for production, it was used the multi-criterion and gradual weight schedule with subsequent application of point method. This thesis revealed defects that have been presented to the representatives of the company's management. It was stated that it is necessary to perform the revision of profit margin because of profit misinterpretation and lower tax payment of corporate income tax. It was clearly demonstrated that the elaboration of transfer pricing documentation is not a useless administrative burden. On the contrary, it is an important base for mapping and analysing inter-company transactions. Correctly elaborated documentation can be used also a negotiation argument with related parties that are usually in a stronger negotiating position or in dealing with financial administration regarding tax inspection.

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.