Transferové ceny v praxi
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Váňová, Ivana
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Vysoká škola báňská - Technická univerzita Ostrava
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Abstract
The Thesis inquires the problems of transfer prices in practice. The theoretical part discovers the elementary principles and methods needed for understanding and proceeding of the comparative analysis individual steps. Each of the five methods for transfer prices determination recommended by the OECD Directive describes the substance of the method, its fortes and weaknesses and possible utilization in practice. In the practical part, a concrete economical relation is solved with usage of a case study, when the main objective is to find out whether prices used among associated companies in controlled transactions comply with the market distance principles and so comply with the common prices conditions.
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Import 11/07/2012
Subject(s)
transfer prices, common price, associated persons, market distance principle, transfer prices creation, transfer prices methods, function analysis, risk analysis, comparable transactions, OECD Directive, model agreement on double taxation avoidance