Transparentnost v převodních cenách

This diploma thesis deals with transfer pricing issues, mainly focuses on the documentary obligations of multinational enterprises, their increasing number in relation to the development of legislation by international organizations and thus, increasing transparency in the transfer pricing environment. From this point of view, it analyzes the model of documentation of transfer prices before BEPS project and the three-tier model proposed by the OECD within the Framework of BEPS project, specifically Action Plan 13. The theoretical part of the diploma thesis is devoted to the clarification of basics of the transfer pricing and legal obligations of multinational enterprises with respect to the documentation of transfer prices and tax administration process. Following characteristics of the model before BEPS and after BEPS provide an overview of the burden of proof of multinational enterprises and outline the increasing burden of proof resulting from the Country by Country Reporting. The practical part comprise a model example of the Country by Country report with commentary to the individual indicators that can be obtained from the respective report and analyzes their impact on the multinational enterprises.