Důkazní prostředky převodních cen

The thesis describes the obligation of elaboration of transfer pricing documentation as the main proof of the correctness of setting up of transfer prices. It analyzes the whole issue in relation to the obligation of a taxpayer. Moreover, it focuses on finding an alternative proves, which can be elaborated with lower effort and will have the same level of relevance. For sake of completeness of the whole issue, the first part of the analysis concentrates on the duties of taxpayers given by law, on proving the facts stated in the tax return of each taxpayer and also its obligations and recommendations in the area of proving the setting up of the transfer prices. The second part of the thesis is dedicated to the process of preparation of an alternative proving instrument with respect to the findings and the minimal possible scope as per the first part of the thesis, for the purposes of minimization of the taxpayer's burden. Further, the Thesis describes the compilation of such alternative proving instrument, based on the existing data processed by internal system of each company. Alternatively, the Thesis defines adjustments in internal systems in order to generate such information automatically in the ordinary course of business and to avoid or minimize additional costs in relation to burden of proof of the taxpayer.