Tax aspects of transfer pricing and its administration

This thesis focuses on the tax issues of transfer pricing, its administration and tax control. The main objective of the thesis is to analyse the procedures of the tax administrator in the tax administration itself and in the tax procedures in the form of audits. The first part of the thesis focuses on a comprehensive theoretical insight into the transfer pricing issue, from the basic pillar of the arm's length principle to the requirements for the preparation of transfer pricing documentation. The second part of the thesis focuses on the area of tax administration and its specificities in relation to transfer pricing, including tax audits. The final part is devoted to selected case law of the Supreme Administrative Court of the Czech Republic and current risk areas, followed by an analysis and description of the tax administrator's approach and recommendations for tax entities.