Převodní ceny z pohledu daňové správy

This bachelor’s thesis focuses on transfer pricing administration in the Czech Republic and the identification of risk areas. Based on data provided by the General Financial Directorate, the thesis evaluates the aggregated results of the tax authority’s audit activities for the years 2015–2024; for the years 2019–2024, these results are also evaluated by transaction type and the country of the related party. The results are supplemented by a questionnaire survey among specialists in the audit departments of the Czech Financial Administration. The empirical section identifies credit financial instruments and license fees as the highest-risk areas in terms of subject matter, while from a territorial perspective, Germany and Asian jurisdictions are the highest-risk. The research revealed significant information asymmetry between the tax authority and taxpayers and a high success rate for taxpayers in appeal proceedings (over 50 %), which is primarily due to challenges to the comparative analyses conducted by the tax authority. The conclusion of the study formulates recommendations – legislative codification of the obligation to maintain transfer pricing documentation and the expansion of safe harbors for tax authorities; for taxpayers, timely preparation of transfer pricing documentation and the use of binding rulings.