Prehliadanie podľa Autor "Brychta, Karel"

Teraz sa zobrazuje 1 - 2 z 2
  • Obrázok miniatúry
    Položka
    An approach for setting a safe harbour for the loans based on freely available data: A reasonable way or just virtue out of necessity
    (Vysoká škola báňská Technická univerzita Ostrava, 2024) Solilová, Veronika; Brychta, Karel; Ištok, Michal
    With regards to strict laws outlined in the Income Tax Act and the lack of specific methodology/guidelines in the OECD Transfer Pricing Guidelines, taxpayers are experiencing significant legal ambiguity and high compliance costs when determining the transfer price of intercompany loans (i.e. transactions between associated persons). For this reason, a number of states have implemented simplified measures, known as “safe harbours“, which offer substantial advantages both for taxpayers and tax authorities. The purpose of this paper is to introduce a potential safe harbour strategy by assessing the predictive capabilities of the Bloomberg and Czech National Bank (CNB) databases in order to establish a safe harbour considering the conditions of the Czech Republic.
  • Obrázok miniatúry
    Položka
    Factors of credit ratings for transfer pricing of loans in European conditions
    (Nakladatelství Oeconomica, Vysoká škola ekonomická : Praha, 2024) Boďa, Martin; Brychta, Karel; Ištok, Michal; Solilová, Veronika
    In accord with international transfer pricing regulations, the borrower's creditworthiness is the main factor to be reflected in valuation of cross-border loan transactions between associated enterprises. However, trouble invariably arises for small and medium-sized enterprises that do not have an assigned credit rating. The aim of this paper is to determine the most reliable predictors of a company's credit rating for European entities facing missing rating coverage for the purpose of transfer pricing. Based on 2015-2019 data sourced from the Orbis database, the study examines key financial ratios and non-financial information that could be instrumental in reconstructing a long-term rating category of a company assigned by Moody's Investors Service. The results identify interest coverage as the most useful predictor. Therefore, a law-approved and tax-acceptable approach to pricing of financial transactions between unrated parties (i.e., without credit rating) should preferably exploit interest coverage as a link to the otherwise missing ratings.