scholarly journals Transfer pricing and the Czech tax policy

2010 ◽  
Vol 58 (6) ◽  
pp. 465-472 ◽  
Author(s):  
Veronika Solilová ◽  
Veronika Sobotková
Keyword(s):  
Czech Republic ◽  
Open Economy ◽  
Tax Policy ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Small Open Economy ◽  
Tax Base ◽  
The Czech Republic ◽  
Eu Member States ◽  
Pricing Rules

The Czech Republic as a small open economy with an extensive network of the international tax treaties for the avoidance of the double taxation prevents from shifting the tax base of the associated enterprises to countries with preferential tax regime through transfer pricing rules. Transfer pricing as one of the important areas of international taxes determines how the profits of the multinational enterprises are split between the jurisdictions in which they operate and which countries get to tax those profits. This situation may affect the global budget of the multinational enterprises and the tax reve­nues of the jurisdictions. This paper is focused on the transfer pricing rules used in the Czech Republic and makes recommendations for the Czech tax policy in this area based on the analysis of the transfer pricing rules in the EU Member States.

scholarly journals Revised OECD Transfer pricing Guidelines and the Czech tax policy

2011 ◽  
Vol 59 (4) ◽  
pp. 301-308
Author(s):  
Veronika Solilová
Keyword(s):  
Czech Republic ◽  
Tax Policy ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Practical Application ◽  
The Czech Republic ◽  
Arm’S Length Principle ◽  
Transfer Prices

In applying the international principles to the taxation of Multinational Enterprises, one of the most difficult issues that have arisen is the establishment for tax purposes of appropriate transfer prices. Transfer prices are significant for both taxpayers and tax administrations because they determine in large part the income and expenses, and therefore taxable profits, of associated enterprises in different tax jurisdictions. The Committee on Fiscal Affairs, which is the main tax policy body of the OECD, has issued a number of reports relating to the transfer pricing issues. The most important are the Transfer pricing Guidelines for multinational enterprises and tax authorities which was published in 1995. These Guidelines focus on the application of the arm’s length principle to evaluate the transfer pricing of associated enterprises, the analysis of the methods for evaluating whether the conditions of commercial and financial relations within Multinational Enterprises satisfy the arm’s length principle and discussion of the practical application of those methods. Simply, these Guidelines focus on the main issues of principle that arise in the transfer pricing area. The Committee on Fiscal Affairs continues its work in this area, on 22 July 2010 approved and released the proposed revisions to Chaps. I through III of these Guidelines and simultaneously published a new Chap. IX related to business restructuring. The revisions are the result of several years of work on comparability and the use of profit-based methods. The revised text will have a significant impact on the application of transfer pricing analysis and transfer pricing methods. The paper is focused on significant changes of newly approved Guidelines with aim to evaluate how the Czech Republic began applying the principles set out in the revised text of these Guidelines.

scholarly journals Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements

2021 ◽  
Vol 69 (2) ◽  
pp. 357-389
Author(s):  
Devan Mescall ◽  
Paul Nielsen
Keyword(s):  
Multinational Corporations ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Empirical Studies ◽  
Annual Reports ◽  
Income Shifting ◽  
Exchange Of Information ◽  
Pricing Rules ◽  
Using Data ◽  
The Impact

Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.

scholarly journals Examination of the Development of New Bus Registrations with Alternative Powertrains in Europe

2021 ◽  
Vol 12 (1) ◽  
pp. 147-158
Author(s):  
Jozef Gnap ◽  
Marek Dočkalik ◽  
Grzegorz Dydkowski
Keyword(s):  
Czech Republic ◽  
Nordic Countries ◽  
Reference Period ◽  
Member States ◽  
The Czech Republic ◽  
Research Results ◽  
Eu Member States ◽  
Eu Directive ◽  
Green Vehicles

Abstract The setting of minimum targets for EU member states to procure green vehicles within two reference periods ending in 2025 and 2030, should help to promote mobility with low, respectively zero emissions. The research results reveal that the V4 countries (Slovakia, Poland, the Czech Republic and Hungary) will find it very difficult to meet the set minimum targets for the share of ecological buses in the total number of buses included in the sum of all contracts subject to EU Directive 2019/1161 concluded from 2 August 2021. The share of buses with alternative powertrains in the V4 countries in 2019 was only 12.79% (with the minimum target being much higher). The Nordic countries are best placed to meet the minimum targets for the share of green buses (in 2019, the share of such buses was almost 19%). The crisis caused by the COVID-19 pandemic, which has and continues to affect bus demand across Europe, may have a significant impact on meeting the minimum targets, especially by the end of the first reference period.

scholarly journals Range data reported to the requirements of the IAS 12 and impact of the IFRS adoption for tax purposes in the tax collection of the Czech Republic

2013 ◽  
Vol 61 (4) ◽  
pp. 961-966 ◽  
Author(s):  
Simona Jirásková
Keyword(s):  
Czech Republic ◽  
Financial Reporting ◽  
Income Tax ◽  
Range Data ◽  
Tax Collection ◽  
Tax Base ◽  
The Czech Republic ◽  
Accounting Regulation ◽  
The Impact ◽  
The Relationship

An issue of relationship between corporate income tax and accounting is one of the most discussed at present. Until recently the tax base was derived from the accounting profit defined in the Czech accounting law. But from 2004 there are companies which have to use IFRS in bookkeeping and financial reporting and from the perspective of the Czech accounting law they do not care about Czech accounting regulation. On the other hand Czech tax regulation has not accepted this change in the field of European accounting harmonization and still directs to pay tax on the basis of Czech accounting regulation for all entities. Fear of adverse change in tax collection is one of the main reasons why the Czech Tax Administration does not allow to pay income tax under profit or loss patterned on IFRS. The most important goal of this work is to characterize the relationship between accounting profit or loss under IFRS and the tax base of income and to find out the impact of taxation under profit in accordance with IFRS in total tax collection. Basic sample of all analyses consists of 35 accounting entities which mandatorily use IFRS and this sample was also confronted with a list of 106 major payers of income tax published yearly by the Ministry of Finance of the Czech Republic for the needs characterization of the relationship of profit under IFRS and the tax base of income.

Local Public Service Delivery Arrangements in the Czech Republic and Slovakia

2016 ◽  
pp. 405-423
Author(s):  
Juraj Nemec ◽  
Jana Soukopova ◽  
Beata Mikusova Merickova
Keyword(s):  
Czech Republic ◽  
Service Delivery ◽  
Public Service ◽  
Main Part ◽  
Public Services ◽  
Final Part ◽  
The Czech Republic ◽  
Local Public Services ◽  
Eu Member States ◽  
New Eu Member States

This chapter discusses the issue of efficiency of the different modes of the provision of local public services in two selected new EU member states – the Czech Republic and Slovakia. The Czech Republic and Slovakia have a long common history and it is feasible to include both of them in the analysis. The first main part of the chapter analyses the history, transformation and the current local public delivery arrangements in the Czech Republic and Slovakia with the focus on the efficiency of the different modes of production. The final part tries to explain the main purposes behind the fact that externalisation does not deliver visible improvements.

Understanding Brand Web Site Positioning in the New EU Member States

2011 ◽  
pp. 99-117
Author(s):  
Shintaro Okazaki ◽  
Radoslav Škapa
Keyword(s):  
Czech Republic ◽  
Multinational Corporations ◽  
Web Sites ◽  
Web Site ◽  
The Czech Republic ◽  
Eu Member States ◽  
Analysis Technique ◽  
Similarity Ratings ◽  
New Eu Member States ◽  
The Web

This chapter examines Web sites created by American Multinational Corporations (MNCs) in the Czech Republic. Utilizing a content analysis technique, we scrutinized (1) the type of brand Web site functions, and (2) the similarity ratings between the home (U.S.) sites and Czech sites. Implications are discussed from the Web site standardization versus localization perspective.

scholarly journals The capital structure of agricultural enterprises in the Visegrad countries

2020 ◽  
Vol 66 (No. 4) ◽  
pp. 160-167
Author(s):  
Veronika Fenyves ◽  
Károly Pető ◽  
János Szenderák ◽  
Mónika Harangi-Rákos
Keyword(s):  
Czech Republic ◽  
Capital Structure ◽  
Regional Cooperation ◽  
Company Size ◽  
Member States ◽  
The Czech Republic ◽  
Agricultural Enterprises ◽  
Eu Member States ◽  
Visegrád Countries ◽  
The Capital Structure

The Visegrad countries – or the V-4 countries: the Czech Republic, Hungary, Poland and Slovakia – is strong regional cooperation of four EU member states in Eastern-Central-Europe aimed at strengthening the positions of the members on both a European and a global level. The aim of this research is to analyse the capital structure of the agricultural and food companies in the V4 Member States. The results show that more profitable companies were less dependent on debt finance, while the fast-growing companies had limited access to the financial market. Company size had a significant effect only in the Czech Republic. Overall, the capital structure seemed to be strongly affected by the farm structure and the relative company size.

The Operational and Environmental Consequences of the Polystyrene Insulation Disposal

2016 ◽  
Vol 824 ◽  
pp. 180-187
Author(s):  
Jan Pasek ◽  
Martin Casensky ◽  
Jakub Stransky
Keyword(s):  
Czech Republic ◽  
Waste Management ◽  
Thermal Insulation ◽  
Legal Framework ◽  
Construction And Demolition Waste ◽  
Management Options ◽  
Demolition Waste ◽  
The Czech Republic ◽  
Eu Member States ◽  
Future Production

In connection with the significant volume of polystyrene embedded in buildings as thermal insulation, in the next few years it will be needed to solve the matter of its disposal after the end of its life cycle. Hexabromocyclododecane (HBCDD) has been used as a flame retardant in polystyrene thermal insulation (EPS and XPS) for the last 50 years. The internationally recognized Stockholm Convention on Persistent Organic Pollutants prohibits future production, use and recycling of materials that contain HBCDD. It also, to a large extent, limits the options of waste management of such materials. European legislation, in particular Regulation (EC) No 850/2004 and the so called REACH Directive, established a binding legal framework for EU Member States which reduces waste management options of material containing HCDBB practically only to incineration. In the coming years, this fact requests fundamental changes in disposal of construction and demolition waste containing the polystyrene insulation and related processes on construction sites in the Czech Republic. The research is based on the analysis of the international and the Czech legislation related to this issue, and the analysis of material and technological context. The paper focuses on possible operational, economic, energy and environmental impact on the construction industry and environment, and compares the current situation in the Czech Republic with other European countries, and assesses the readiness of the Czech Republic to deal with the upcoming legislation changes.

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