The Transfer Pricing in Selected Business Enterprise

This diploma thesis deals with the issue of transfer pricing. Based on the performed functional, risk and comparative analysis, it proposes recommendations to the company leading to the elimination or mitigation of identified risks. The selected enterprise and its group are characterized by performing a functional and risk analysis, it is characterized and on this basis the transactions taking place within the group are analyzed. These transactions are compared with the market environment of comparable companies. On the basis of the calculated market profit range, conclusions are made about compliance with the market distance principle. Part of the overall analysis is also an analysis of the comparison of margins for products sold within the group, which is also compared with the margins charged to unrelated parties to explain the sales strategy of the selected company. According to the information obtained from the analysis of the company's financial environment, the main risks to the company resulting from the market environment and poorly set transfer pricing policy are outlined. After carrying out the given procedure, it was found that the company complies with the principle of market distance in the examined years, however, the business policy setting requires the introduction of strict control over the future development of the transfer price