Převodní ceny v podnikové praxi

The bachelor's thesis deals with transfer pricing in corporate practice and the importance of the correct setting and documentation of transfer prices during tax audits. Transfer pricing is a strictly monitored topic from the perspective of financial authorities and tax administrations. Incorrectly set transfer prices and insufficient defense can be quite costly for companies when assessing the tax. The thesis aims to identify risks in transfer pricing according to the company's functional and risk profile and to find a solution that meets the requirements of Czech tax legislation and withstands a tax audit focused on transfer pricing. The first part of the thesis defines terms and legislation related to transfer pricing and formal requirements for the scope of transfer pricing documentation. Furthermore, it presents the basic methods of determining transfer prices according to the OECD Transfer Pricing Guidelines and describes the basic functional profiles of enterprises. The practical part of the thesis contains model examples of transfer pricing in practice, its risks, and eliminating these risks following the methodology of current practice.