| Popis: |
ISSUES OF TRANSFER PRICING Transfer pricing has been often-discussed topic in recent years which is unlikely to change in the upcoming years. Given the great importance of transfer pricing in international tax planning, as well as in so called aggressive tax planning, it is a priority for states to set transfer pricing rules based on the arm's length principle in such a way that untaxed profits are not transferred from the jurisdictions where it was generated. Although this is a tax issue concerning the direct taxation, it shall be regulated at least in a coordinated manner by most countries in the world, as the international overlap is the greatest danger to state treasuries. From the perspective of taxpayers, it is often very difficult to meet all obligations regarding the setting of transfer pricing pursuant the arm's length principle, but it can be pointed out that a sufficiently clearly specified rules may be in favor of the taxpayers, because unjustified price manipulation between the related parties may cause some distortion of the functioning of the market. The main purpose of this thesis is to provide a comprehensive overview of transfer pricing issues from the perspective of Czech legislation, especially the Income Tax Act and instructions issued by the Ministry of Finance and the... |
