Daňový dopad na ekonomický subjekt při nesprávném stanovení převodních cen
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Vysoká škola báňská - Technická univerzita Ostrava
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Abstract
This thesis focuses to identify the theoretical aspects and practical implications of transfer pricing. The aim of the thesis is to show potential possible of tax impact from business transactions between associated companies on the grounds of incorrectly determination of transfer prices. The theoretical part decribes the principle of transfer pricing and the form to eliminate the risks related with transfer pricing. The following are defined of basic transfer pricing methods mentioned in the OECD. In the practical part is solved the tax impact related with business transaction between czech company and associated enterprise. Czech company is also recipient of investment incentives and this fact intensifies the total amount of tax impact. The last of the practical part is the quantification of total tax ompact resulting in loss of investment incentive - tax credit.
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Import 26/06/2013
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transfer prices,transfer pricing guidelines,transfer pricing methods,arm´s length principle, associated enterprises, double taxation, tax haven,tax profit