Problematika garancí mezi spojenými osobami v rámci převodních cen

This thesis aims to present general approach for assessment of financial guarantees between associated companies in the context of transfer pricing. The text describes essential legislation in the Czech Republic and the international regulation concerning transfer pricing, which is subsequently specified in the area if financial guarantees. In the practical section of the thesis, an approach for the assessment of a guarantee fee between associated companies in the sense of its compliance to the arm’s length principle is demonstrated. The model situation is built to show possible considerations when facing the issue of insufficient data in the Bloomberg database, which was chosen as the main source of data, that can be used for the transfer pricing analysis of financial transactions. The chosen approach led to the quantification of a guarantee fee that is in accordance with the arm’s length principle, however with the subsequent expression of some deficiencies of the performed assessment.