H25 - Business Taxes and Subsidies including sales and value-added (VAT)Return

This paper deals with the definition of the role of a tax advisor and his duties, the definition of the role of an expert and his duties, with an emphasis on the area of transfer pricing. The article mainly explains their different points of view and the different informational quality of their outputs - transfer-pricing documentation and expert opinions. The article also deals with the role and usefulness of expert opinions in tax proceedings.

The article deals with the core area of transfer pricing, which is functional and risk analysis. It summarises the current regulation in the Czech Republic and presents a recommended approach. Using a case study, the authors demonstrate the practical application and highlight some specific situations that may be encountered in practice.