Oceňování, 2022 (vol. 15), issue 4

Articles

Intra-group financing from a transfer pricing perspective

David Hejduk, Barbora Rýdlová

Oceňování 2022, 15(4):3-14 | DOI: 10.18267/j.ocenovani.282  

This article discusses the topic of intra-group financing and is specifically focusing on the area of intra-group loans from the point of view of transfer pricing. The article introduces the reader to this topic first in general including its placement in legislative and other contexts. Furthermore, the text deals with specifics of financial transactions, their concept in terms of transfer pricing, including the introduction of individual components of transfer pricing analysis in this area. At the end of the article, the conclusions resulting from the comparative analysis of a particular debt transaction are summarized, including recommendations for...

Transfer Pricing - Functional and Risk Analysis

Jiří Hlaváč, Lukáš Pěsna, Veronika Kdolská

Oceňování 2022, 15(4):15-24 | DOI: 10.18267/j.ocenovani.283  

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.

Assessment of Transfer prices by expert or tax advisor

Jiří Jakoubek, František Poborský, Jiří Teichmann

Oceňování 2022, 15(4):25-32 | DOI: 10.18267/j.ocenovani.284  

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.

Case study - specifics of transfer pricing in the context of enterprise valuation

Boris Mišun, Karin Mašková, Marek Jindra

Oceňování 2022, 15(4):33-43 | DOI: 10.18267/j.ocenovani.285  

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...

Approaches and methods of valuation of intangible assets - a comparison of the OECD Transfer Pricing Guidelines and International Valuation Standards

Pavel Svačina

Oceňování 2022, 15(4):44-60 | DOI: 10.18267/j.ocenovani.286  

This paper discusses the differences in intangible asset valuation approaches and methods enshrined in the OECD Transfer Pricing Guidelines and International Valuation Standards. The paper identifies some overlap, but also significant differences both at the level of the concept (category) of value and at the level of the main valuation methods themselves. At the level of the methods themselves, the typology of the main methods and their internal principles are compared. Special attention is given to the substantially different concept and use of the concept/method of profit-split between the IVS and the OECD.