tax optimisation, multinational enterprises, transfer prices, transfer transactions, retrospective assessment
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.