Vnitropodnikové kalkulace pro účely stanovení převodních cen na případu společnosti Fresenius Kabi Horatev CZ s.r.o

This bachelor's thesis addresses the interconnection between internal cost accounting and transfer pricing issues using the case of Fresenius Kabi Horatev CZ s.r.o., a company that operates as a contract manufacturer within the multinational Fresenius group. The aim of the thesis is to identify the main risks associated with transfer pricing setup, to assess the suitability of individual methods in relation to the company's functional and risk profile, to propose a method for verifying compliance with the arm's length principle, and to quantify the financial impacts of selected risk scenarios. The theoretical part defines the legislative framework of transfer pricing, the methods of their determination according to the OECD Guidelines, and the issues of managerial accounting and cost calculations. The practical part includes a functional and risk analysis of the company, an examination of the COP costing system used, an assessment of individual transfer pricing methods, and a methodological proposal for a comparability analysis in the Orbis Europe database. The financial impacts of the identified risks are subsequently quantified through a sensitivity analysis across three scenarios. The results showed that the most serious risk is the reclassification of the transaction as toll manufacturing, followed by the risk of an overvalued mark-up, while also demonstrating the close link between the setup of cost calculations and the level of the transfer price.