Uplatnění principu tržního odstupu v případě „limited-risk“ distributorů

This thesis addresses the issue of the applicability of the arm's length principle in the case of so-called "limited-risk" distributors. In the first part of the thesis, the legislative basis of the Czech Republic and international regulation in the field of transfer pricing is described, focusing on the arrangement of limited-risk distributors. In the practical part, a comparative analysis using the TNMM method is first introduced on a model case of a limited-risk distributor, and an alternative in the form of using the PSM method is also introduced for the same model case. The results of both analyses were then compared. In conclusion, the individual advantages and disadvantages of both methods were evaluated, the reliability of the results was assessed, any question of their mutual complementarity was answered, and general practical recommendations were constructed for the similar arrangements of limited-risk distributors.