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Transfer pricing between related parties and its issues
Čech, Prokop ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Transfer pricing between related parties and its issues As the globalization of the world continues, and as the companies are merging into multinational enterprises, the number of transactions between related parties under circumstances that would not be concluded between unrelated parties is rising. The correct application of transfer pricing between related parties ensures that the transactions are concluded as it would have been between unrelated parties. More and more attention is paid to issue of transfer pricing, frequently in connection with tax planning and tax optimization, which is partly misleading. The tax consequences of transfer pricing are nonetheless substantial. The purpose of this thesis is to analyse transfer pricing issues in the Czech Republic in the context of international rules and standards as set by international organizations, mainly Organization for Economic Cooperation and Development (OECD), United Nations (UN) and European Union (EU), primarily from the tax perspective. The thesis is composed of 11 chapters. In first chapters the thesis describes the basics of transfer pricing, the concept of related parties, arm's length principle, transfer pricing methods and transfer pricing documentation. The next chapters are mainly focused on international transfer pricing...
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Taxation of income of natural persons (comparison of legislation in the CR and selected EU countries)
Boušková, Natalie ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
Taxation of Personal Income (a comparison of the legislation in the Czech republic and selected countries of EU) The topic of taxation of personal income has been chosen by the author of this diploma thesis. The original purpose was to describe and analyze the legislation in two states, Czech Republic and Slovak Republic, which had existed as a common state more than 70 years in the 20th century. Therefore it could be interesting to follow up, what had happened during the last 20 years after the disintegration of the common state. This thesis is divided into five parts (including an introduction and a conclusion), which are generally subdivided into the chapters and subchapters. The thesis was written in accordance with the law applicable on the 1st October 2013. In the first part of the thesis, the author deals with the Czech laws regulating an income tax of individuals. She defines and briefly explains an essential terminology related to that part of legislation including some proposed amendments of the Acts. As a main source the Law on Income Taxes, no. 586/1992 was used. It is important to highlight also the chapter number 4 which is focused not only on the Czech territory, but which analyses the problem with an international double taxation of worldwide incomes of a natural persons, including...
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Time limits in tax administration
Alexa, Karel ; Marková, Hana (advisor) ; Novotný, Petr (referee) ; Karfík, Zdeněk (referee)
Time limits in tax administration Time limits have an irreplaceable role in law. They are of a crucial importance especially in situations where a certain act (exercise of a right or a fulfillment of obligation) is limited by time so that after a certain time expiration it is possible to state that such an act was not performed and thus to draw legal consequences hereof. The main purpose of a time limit is the demarcation of the state of uncertainty as to whether the act will be performed or not and thus to determine either the legal consequence of the performance of the act or the consequences of the default of time. It is clear that the tax proceedings legislation also needs its time limits. Quite frequently it is necessary to set a certain time period for the performance of an act. This time period is set by a time limit. Otherwise it would be only possible to state that an act has already been performed or not yet been performed. It would however not be possible to state that the act was supposed to be performed, i.e. if a person who could have acted or was supposed to act, in fact did not act, the whole process of administration of taxes would come to a deadlock. The aim of this thesis is, firstly, to generally analyze the concept of time limits. The legal sciences deal with the general...
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Analysis of strenght training of rock climbers - campusing
Malý, Jiří ; Kračmar, Bronislav (advisor) ; Novotný, Petr (referee)
Title: Analysis of strenght training of rock climbers - campusing Objectives: The main objective of this work is to determine time and space characteristic of working muscle chains of upper body during training on campus board and climbing on vertical wall. Comparing basic exercise by measuring EMG signal in combination with cinematographic analysis synchronized with video record, to analyse coordination markers of muscle work in selected area of movement system. Methods: In our thesis we used a method of analysis and a method of comparison. We apllied the method of analysis in research of campusing movement and the method of comparison in comparing the basic climbing movement and basic campusing. Results: It is possible to define campusing as movement in vertical axis, which is executed by three times faster muscle chains activation compared to basic climbing on vertical wall. Movement is realized by upper limbs, by changing positions of one point holding position and two point holding position. In both activities measured muscles are wireing in similar mode, during campusing the musculus pectoralis major and the musculus triceps brachii are faster in start of their activity compared to climbing on vertical wall. Keywords: sport climbing, muscle chains, electromyography, campusing
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The tax system and agreements on the avoidance of double taxation
Kohoutová, Petra ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
1 Abstract: The tax system and agreements on the avoidance of double taxation This diploma thesis "The tax system and agreements on the avoidance of double taxation" is focused on practical issues in the field of using international corporate structure in order to decrease the tax liability applicable on entrepreneurs. The diploma thesis includes the basic description of the legal rules applicable in the Czech Republic, such as acts and also international treaties. In the field of EU law, the diploma thesis described briefly EU directives based on which it is possible to transfer dividends, interest and royalties between mother and daughter companies without withholding tax payable in the Czech Republic. International treaties described in this diploma thesis were double taxation avoidance treaties between the Czech Republic and Cyprus and between Cyprus and Seychelles. First part of the diploma thesis is describing legal regulation of income taxes applicable in the Czech Republic. It is aimed mainly on interests, dividends and royalties. The first part of the diploma thesis is of theoretical nature which gives basics for the second and third part which practically analyze possibilities to decrease tax burdens of entrepreneurs. Second part of the diploma thesis brings analysis of individual model situations...
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Selected Plants of the Rose Family (Rosaceae) and their use within Teaching of Biology
Kučerová, Jana ; Skýbová, Jana (advisor) ; Novotný, Petr (referee)
Selected Plants of the Rose Family (Rosaceae) and their use within Teaching of Biology The main topic of this bachelor thesis are plants of the Rose Family (Rosaceae).The thesis is divided into several parts. Firstly the general characteristics of the family are introduced. At the following part there is analysis of textbooks for elementary and secondary schools in terms of representation of plants from Rose Family (Rosaceae), whose purpose was to determine what information the reader will learn about the family and its individual representatives from the textbooks mentioned. Plants, herbs and woody species which occur in the textbooks the most are further characterized in details. There is their description, information about expansion, application in medicine, there are stated some interesting points from history, but also explanation of their educational use in teaching. The work is complemented by suggestions for laboratory exercises and worksheets for pupils of elementary schools and students of secondary schools. Key Words: Rose family (Rosaceae), Analysis of textbooks, individual representatives of Rose Family, didactical topics
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Liberalization of restrictions upon the acquisition of real property by foreigners in the Czech Republic
Krylová, Jana ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
The purpose of this thesis is to analyse the progress and development connected to the acquisition of domestic real estate by foreign exchange non-residents, especially the changes in legal regulations which deal with this issue, and to document this liberalisation with examples from court procedures. This thesis comprises seven chapters; the first two chapters are designated for the introduction, where the goals of this thesis are defined, and for a short historical excursion which introduces the issue from a historical context. The core of this thesis is chapters three, four and five. Chapter three describes and evaluates the development of this issue in the period between November 1989 and the adoption of the last Foreign Exchange Act. The most attention is paid to the dynamic development of the regulations in the Foreign Exchange Act and on the context of other matters which had a large impact on its provisions. The purpose was to order the single chapters and subchapters so that they constitute a logical unit on the one hand, but on the other hand each subchapter deals with its own topic and part of the issue. Logical milestones are events like the Accession of the Czech Republic to the European Union and the expiration of transitive periods. Factually the single subchapters deal with special...
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Taxation of freelance artistic professions in the Czech Republic between 2007 - 2013
Šich, Jaroslav ; Vondráčková, Pavlína (advisor) ; Novotný, Petr (referee)
V anglickém jazyce: The subject of my rigorous thesis consists in complex analysis of the matter of taxation of freelance artistic professions in the Czech Republic (and also concisely in the European Union and Ireland) within the monitored years from 2007 to 2013, whereas I have chosen this period particularly due to the reason that this period demonstrates very aptly the variability of state approach to the taxation of self- employed and freelance persons reflecting wide scale of changes to the Czech tax legislation. In my rigorous thesis, I have primarily focused on the illustration of current state of Czech tax legislation and further on the thorough analysis of crucial amendments to the tax regulations, whereas I have also professionally reviewed the impact of those changes including the introduction of factual comparative indicators. Following the execution of analysis of the above defined subject, I have drawn a conclusion in which manner the regulation of taxation of artists may be administered. Among the measures proposed by me pertains for instance the elimination of the minimum assessment basis for social insurance payments, whereas the artists would be obligated to pay the social insurance merely from the actually achieved tax basis, or the increase of expenses allowance for artists to...
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Made of three dimensional teaching aids
Strnadová, Kristýna ; Řezníček, Jan (advisor) ; Novotný, Petr (referee)
This work deals with vertebrates bone preparation of birds and mammals to enrich the science classes at secondary school. It also expands the collection of vertebrate skeletons at the department of biology and enviromental studies. The display would be enriched by Talpa europea, apodemus sylvaticus, rattus rattus, alectoris rufa and skulls of octodon degus. In this work there are described ways how to prepare taxidermy and bone preparation is described from the beginning of collecting vertebrates, then methods of preparation (maceration, hot water maceration, dermestidae bettles and more) including degreasing and bleaching and final treatment not the get it damaged by insect. This work is completed by survey. There are involved teachers of biology at elementary schools. The idea of questionnaire was to find out what's equipment like and how often do teachers use nature products to enrich the lessons. Key words - taxidermy, osteological preparation, birds, mammals
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