K34 - Tax LawReturn

Transfer pricing is a complex topic with links to other disciplines, not just economics. The aim of this paper was to present considerations concerning the interdependence between transfer pricing and the value of the company/enterprise in the form of case studies. Obviously, there is no one right solution to some issues and the approach of tax and valuation experts may differ, so the intention was mainly to highlight some specific areas and open up discussion rather than to draw a clear conclusion.
From a valuation perspective, one of the basic assumptions in transfer pricing is to take into account the required return on invested capital as presented in the case studies.

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.