Návrh stanovení politiky transferových cen v obchodní společnosti

Abstract

This bachelor thesis deals with the proposal of transfer pricing policy in a trading company. At the beginning, basic concepts and legislative regulations regarding transfer pricing are explained together with basic principles of Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration and agreements on avoidance of double taxation and transfer pricing setting. The next part is devoted to functional analysis which describes the process of purchase and sale of goods within company group, its logistics, IT processes, administrative services and the process of financing dependent entities in the group. Comparative analysis dealing with characteristics of the subject transaction, analysis of functions performed, borne risks, used assets, contract terms and business strategy. The method for transfer pricing setting is chosen. Finally, the choice of method of prices setting between parent company and its subsidiaries is proved.