Problematika převodních cen v podnicích České republiky

Specific questions from the area of international taxation of multinational enterprises and corporations implicate mainly enterprises associated in groups. Transfer pricing is one of the important areas of international taxation, which can be explained from an aspect of a tax administrator on one hand and of international enterprises as a tax payer on the other hand. Tax optimisation is a general term, which could be sometimes understood in a meaning to decreasing of a tax liability. In the paper there are introduced basic aspects of an international taxation of multinational enterprises. This comes from a principle that a correct transfer price should be a compromise of an international enterprise and tax administrator. The next chapter focuses on the situation in the Czech Republic. There is regularized a question of transfer prices of associated enterprises by Guideline of Ministry of Finance of the Czech Republic No. D-258. This Guideline formally derives form the directive of OECD, which is a guideline or instruction for concerned subjects. There is shown a practical example of economic implication on Škoda Auto, a.s. The next part of the paper describes a current situation in the international context, which has been presented in some scientific documents of consultancy firms. There are several global trends in the world and question of transfer pricing has becoming a very important activity of tax authorities. The conclusion of the paper outlines risky situation in financial conditions of a selected firm resulting from a retrospective assessment by reason of the transfer prices.