Due Diligence převodních cen holdingové struktury a vliv na strategii a hodnotu firmy

This thesis examines transfer pricing due diligence within an anonymized holding structure operating in the automotive parts manufacture segment, in the context of a potential acquisition. The aim of the thesis is to assess whether the intercompany transactions of the analyzed entity comply with the arm's length principle, identify potential tax risks, and quantify their impact on the company's value and liquidity. The theoretical part defines the legislative framework for transfer pricing, describes the methods for their determination, and characterizes the functional profiles of the analyzed entities. In the practical part, a functional and risk analysis is used to determine the functional profile of the analyzed entity as a contract manufacturer, while a benchmarking analysis identifies a deviation from the arm's length principle in the main transaction. The impact of the identified risk is subsequently quantified through the calculation of a tax assessment and the EV/EBITDA multiple method. The results demonstrate that incorrectly set transfer prices pose a risk not only in terms of equity value, but also in terms of the company's liquidity and its attractiveness to a potential acquirer.