Stanovení obvyklé úrokové sazby ve vnitroskupinovém financování v podmínkách ČR

Master’s thesis deals with the topic of financial transactions, more precisely it focuses on the area of intra-group loans within the topic of intra-group financing. The main objective of the master’s thesis is to evaluate various possible approaches of the taxpayer in the Czech Republic to prepare a comparative analysis of an interest rate (a transfer price of an intra-group loan) and to propose a suitable approach that would ensure defensibility of this transfer price before the tax administration and that would at the same time reflect all the key factors that should be reflected in such an analysis. The secondary goal of this thesis is to offer the reader a comprehensive elaboration of the transfer pricing issue of intra-group financing with the focus on intra-group loans, including the introduction of this topic in the context of financial management of multinational enterprises operating in a group of companies. The theoretical part of this thesis is divided into two chapters. While the first chapter generally defines the area of transfer pricing, the second chapter deals with the issue of intra-group financing. The second chapter further defines the individual aspects of intra-group loans and components of transfer pricing analysis in this context, such as the characteristic of intra-group loan arrangements including the perspective of the borrower and the lender, credit rating, transaction (loan) volume, and available methods for assessing the transfer prices of intra-group loans. At the end of the theoretical part of this master’s thesis, the last subchapter is devoted to the issue of cash pooling, which is one of the most widely applied financial management solutions in groups of associated companies. The practical part of this thesis introduces a comparative analysis of a transfer price within a specific intra-group credit transaction in a group of associated companies. The practical part is divided into chapters three and four. In the third chapter, a comparative analysis is performed, including the delineation of the assessed transaction, credit rating determination, functional and risk analysis and transfer price analysis using comparable uncontrolled price method and economic modeling method while applying three alternative approaches – Bloomberg database, CNB ARAD database and a cost of debt model. The fourth chapter summarizes the results of the approaches mentioned above and offers a systematic evaluation of the individual approaches based on defined parameters, including a synthetic parameter of the defensibility of the respective approach and related results before the Czech tax administration. The conclusion of the chapter presents a recommendation to the Czech taxpayer regarding the most suitable approach to the evaluation of transfer prices of intra-group loans.