Problematika stanovení převodních cen
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Vysoká škola báňská - Technická univerzita Ostrava
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Abstract
The thesis deals with the issue of transfer pricing. In other words, the thesis deals with the pricing process which is used in transactions between related parties. The aim of the thesis is to show how to proceed in determining the transfer price and justifying the comparability of transfer prices with market prices (arm's lenght principle). To fulfill the goal of the thesis a transfer pricing documentation for the production company is created. The partial aim of the thesis is also to select a suitable method and identify problems with its application.
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Transfer Pricing, Associated Company, Transactions with External Companies, Arm’s length Principle, Transfer Pricing Documentation, Functional Analysis, Transfer Pricing Methods, common price, OECD Directive, model agreement on double taxation avoidance