Transferová cena pro sdílené IT služby

Bachelor’s thesis deals with the topic of transfer pricing with a focus on low value-adding intra-group services. The theoretical part is divided into two chapters. The first chapter is focused on the general characterization of transfer pricing with an emphasis on the fulfilment of the arm’s length principle when determining a transfer price. The focus of the second chapter is on low value-adding intra-group services. The practical part of the bachelor’s thesis deals with a calculation of a transfer price for shared IT services provided by an IT department within a group of companies. The third chapter specifies the cooperating company and the role of the IT department within the group. Further, in chapters four and five the practical part of the thesis deals with the specification of approaches to determination of a transfer price for services in question. Chapter five focuses on the calculation of the transfer price according to all introduced methods and illustrates the calculation on an example of a real client company that buys these services. At the end of the practical part, the described approaches are evaluated and compared. Using an analysis of recommendations, guidelines, and legislation in connection with low value-adding intra-group services, this thesis aims to introduce possible approaches to determining a transfer price for such services, present its calculation and recommend which method is suitable under given circumstances.