Specifika převodních cen v daňových kontrolách

My thesis deals with the specifics of tax audit on transfer pricing. The main objective of my thesis is to analyse judgments of the Supreme Administrative Court which deal with the issue of transfer pricing and on their basis to identify the most frequent disputes between taxpayers and the tax administrator in this particular area. The first chapter of my thesis is devoted to the general description of transfer pricing, its legal regulation and outlining current transfer pricing issues. The second chapter discusses tax audit, it analyses available statistical information, defines tax audit in its specific stages and presents the means of defence of the taxpayer. The third and key chapter of the thesis begins with analysis of the available statistical data on tax audits on transfer pricing, then summarises the content of the Supreme Administrative Court judgments, and finally in detail discusses the most frequent disputes between taxpayers and the tax administrator, together with indicating their causes, concluding with specific recommendations for preventing mentioned disputes.