The Application of Trends of Transfer Pricing Adjustments of Selected European Countries in the Czech Republic

/ Résumé / Zusammenfassung Transfer pricing is currently a very relevant topic. Tax administrations are focusing on unveiling and penalizing tax evasion and in author's opinion also on prevention and reduction of tax optimization using intragroup transactions with price designed to minimize taxation. The volume of tax base and tax adjustments by tax administrations multiplied in recent years without significant changes in relevant legislation and that raises a question whether this change is not contrary to the principle of legality use of powers conferred by public law. This thesis analyzes reasons for these changes, which are connected to significant increase in number of group cross border transactions. In European context the increase is partially result of intensive economic integration of member states. Second important aspect leading to the relevance of this topic is the intensity public perception of this issue which to large extent eliminates the difference between tax avoidance and illegal tax evasion. The thesis generally focuses on transfer pricing in European context created by the activities of OECD reflected by EU legislation. The analysis shows that the OECD document on the issue are very beneficial instruments and their use is in many cases unified by the EU, which analyzes the..