Transfer Pricing Regulation and Application to Multidivisional Company

Ing. Tamari Kaikatsishvili

Master's thesis

Abstract:

The thesis investigates the significance of Transfer Pricing mechanism by identifying and measuring its impact on financial performance of multinational enterprises. The study is divided into three parts. The first part provides theoretical evidences on Transfer Pricing methodology. Particularly, defines TP methods and clarifies a strategy of choosing most suitable Transfer Pricing method under certain circumstances. In the second part, the study employs the combination of the qualitative and quantitative methods to analyze the performance of the real business enterprise, its functions and risks in terms of Transfer Pricing model. Comparability analysis is based on information retrieved from AMADEUS database and most suitable comparable unrelated companies are selected to maintain accurate Transfer Price. The third part postulates pertinent recommendations, with respect to the consequences derived from the comparability analysis, which are elaborated in accordance with legislations and policies of the countries, where the tested enterprises operate.

Keywords

Transfer Pricing, transaction-based methods, transactional profit methods, comparability analysis, advance pricing arrangement

Language used: English

Date on which the thesis was submitted / produced: 17. 5. 2017

Thesis defence

• Date of defence: 21. 6. 2017
• Supervisor: Ing. Petr Valouch, Ph.D.
• Reader: Ing. Oleksandra Lemeshko

Masaryk University

Faculty of Economics and Administration

Master programme / field:
Finance and Accounting / Finance (eng.)