This work focuses on methods of the transfer pricing identification, in connection with the possibility to find comparable independent data on the market. In the first part, the author describes the basic ideas and the main legislation resources both in the Czech Republic and internationally. It also describes the main methods of the transfer pricing identification mentioned in the Transfer Pricing Guideline. Second part examines the method's application, which depends mainly on the type of the controlled transaction as well as on the comparable data availibility. Third part relates to the model case, which shows in detail the complete process of the transfer pricing identification. Each process includes the functional analysis of related parties, choosing the best possible method and the comparable analysis, which focuses on the searching out the independent comparable companies.
| Identifer | oai:union.ndltd.org:nusl.cz/oai:invenio.nusl.cz:11787 |
| Date | January 2008 |
| Creators | Plešingerová, Jana |
| Contributors | Francírek, František |
| Publisher | Vysoká škola ekonomická v Praze |
| Source Sets | Czech ETDs |
| Language | Czech |
| Detected Language | English |
| Type | info:eu-repo/semantics/masterThesis |
| Rights | info:eu-repo/semantics/restrictedAccess |
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