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Aspekty stanovení převodních cen v podmínkách ČR / Aspects of transfer pricing in the Czech Republic

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.

Identiferoai:union.ndltd.org:nusl.cz/oai:invenio.nusl.cz:251774
Date January 2016
CreatorsZÍTKOVÁ, Božena
Source SetsCzech ETDs
LanguageCzech
Detected LanguageEnglish
Typeinfo:eu-repo/semantics/masterThesis
Rightsinfo:eu-repo/semantics/restrictedAccess

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