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Don't pay taxes, save your money!
Bradáč, Michal ; Kemény, Irena (advisor) ; Gregor, Martin (referee)
Bachelor thesis "Don't Pay Taxes, Save Your Money!" focuses on the impact of the existence of tax havens on private and public sector. On the theoretical level, it shows the attractivity of tax havens for sufficiently large firms that can afford to pay costs of tax planning and profit manipulations. On the empirical level, it shows that tax havens are really the most successful jurisdictions in attracting foreign investors. In the end, two models of tax competition are introduced in order to describe the importance of tax competition for the whole economy. Keywords:Tax Haven, Tax Avoidance, Tax Competition
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Implementation of ATAD
Knetl, Štěpán ; Boháč, Radim (advisor) ; Vybíral, Roman (referee)
The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Directive (ATAD). It firstly introduces the problem of tax avoidance, its scale and defines basic concepts such as tax avoidance, tax evasion, tax havens and harmful preferential tax regimes. The author consequently describes origins of the Directive, OECD's Base Erosion and Profit Shifting Actions and other measures that are being implemented on the EU level such as international exchange of information in the field of taxation based on DAC Directives, the proposal of CCCTB. In the second chapter the ATAD is presented. It consists of five measures intended to neutralize the effects of tax avoidance practices, or in other words, to prevent erosion of the CIT base and the shifting of profits to jurisdictions enforcing little or no tax liabilities. First measure proposed is the interest limitation rule. It is intended to prevent the use of debt financing as a form of tax avoidance by limiting the amount of the tax-deductible borrowing costs that an entity is allowed to claim. Second measure is the exit taxation rule that requires the Member States to tax unrealised appreciation of assets based on the difference between amount equal to the market value of the transferred asset at the time of exit of the...
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Determinants of the Demand for Tax Haven Operations: Empirical Evidence from the Czech Republic
Burianová, Markéta ; Janský, Petr (advisor) ; Švarcová, Natálie (referee)
The aim of this thesis is to explore the firm-specific determinants of the demand for tax haven operations by Czech firms. Our objective is to better understand the firms' incentives for tax haven use, and furthermore whether there exists cross-haven heterogeneity in those incentives. The thesis examines the firms' tax haven investment behaviour by analysing firm-level data for 15,530 Czech firms for year 2013. To the extent of our knowledge, this has been the first research of its kind devoted to Czech firms. The evidence suggests that larger, more profitable firms with larger international presence are most likely to use tax havens. The analysis also indicates that higher firm indebtedness is associated with greater likelihood of establishing tax haven operations. This would suggest Czech firms engage in profit shifting through the use of debt financing. Furthermore, service firms were found to be more likely to use tax havens than manufacturing firms. This contrasts with previous research where R&D intensity was a leading indicator of tax haven use. Additionally, we found significant cross-haven heterogeneity in the determinants, particularly in the sector-specific characteristics. In our sample, service firms favoured Cyprus and the Netherlands, while manufacturing firms preferred Luxembourg...
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How Much in Taxes Do Multinational Enterprises Pay?
Boukal, Tomáš ; Janský, Petr (advisor) ; Palanská, Tereza (referee)
Taxation of multinational enterprises accounts for a significant portion of government revenues. These revenues are however negatively affected by the tax behavior of many multinational groups which shift significant part of their profits to tax haven countries. The prevailing body of the literature on this topic has focused on the quantification of shifted profits and the resulting tax losses. Thus, the question of how much multinational enterprises do pay on taxes has remained unanswered. This has changed with the recent publications of Bolwijn et al. (2018) and Tørsløv et al. (2018). The aim of this thesis is to discuss their methodologies, apply them and present the amount of taxes paid by foreign affiliates of multinationals in individual countries. We express the results as a portion of GDP to enable cross-country comparison and put them in contrast to the estimates of tax losses from profit shifting. Keywords multinational enterprise, corporate income tax, international taxation, government revenue, tax avoidance
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Implementation of ATAD
Knetl, Štěpán ; Boháč, Radim (advisor) ; Vybíral, Roman (referee)
The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Directive (ATAD). It firstly introduces the problem of tax avoidance, its scale and defines basic concepts such as tax avoidance, tax evasion, tax havens and harmful preferential tax regimes. The author consequently describes origins of the Directive, OECD's Base Erosion and Profit Shifting Actions and other measures that are being implemented on the EU level such as international exchange of information in the field of taxation based on DAC Directives, the proposal of CCCTB. In the second chapter the ATAD is presented. It consists of five measures intended to neutralize the effects of tax avoidance practices, or in other words, to prevent erosion of the CIT base and the shifting of profits to jurisdictions enforcing little or no tax liabilities. First measure proposed is the interest limitation rule. It is intended to prevent the use of debt financing as a form of tax avoidance by limiting the amount of the tax-deductible borrowing costs that an entity is allowed to claim. Second measure is the exit taxation rule that requires the Member States to tax unrealised appreciation of assets based on the difference between amount equal to the market value of the transferred asset at the time of exit of the...
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Tax aspects of trust fund
Veverková, Tereza ; Kohajda, Michael (advisor) ; Sejkora, Tomáš (referee)
The objective of this thesis is to place trust fund into the system of tax law and the analyse of this position from different angles. The main objective is to describe, how are trust funds and the persons connected with them, taxed. One of the aims of this thesis is to show trust funds within a broader context and therefore it describes the tax aspects of English common law trust as well. Common law trust can be considered as a role model for institute like the Czech trust fund. The thesis therefore consists of two parts - trust and trust fund. The first chapter describes historical development of trusts and illustrate how was this development influenced by then tax legislature. Also, this chapter explains some aspects of English law, with focus on difference between common law and equity. The grasp of the difference between these parallel systems is essential for the understanding of trust. The second chapter deals mainly with substantive aspects of trust. It strives to answer the question, what is trust and how can we definite it. It also shows, how the tax legislature defines trust and connected person for tax purposes. It is also briefly mentioned the duty of trust to register into newly established trust register. The third chapter deals with taxation of trust itself. Different types of trusts and...
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The Application of Trends of Transfer Pricing Adjustments of Selected European Countries in the Czech Republic
Nekovář, Jiří ; Karfíková, Marie (advisor) ; Boháč, Radim (referee) ; Bělohlávek, Alexander (referee)
/ Résumé / Zusammenfassung Transfer pricing is currently a very relevant topic. Tax administrations are focusing on unveiling and penalizing tax evasion and in author's opinion also on prevention and reduction of tax optimization using intragroup transactions with price designed to minimize taxation. The volume of tax base and tax adjustments by tax administrations multiplied in recent years without significant changes in relevant legislation and that raises a question whether this change is not contrary to the principle of legality use of powers conferred by public law. This thesis analyzes reasons for these changes, which are connected to significant increase in number of group cross border transactions. In European context the increase is partially result of intensive economic integration of member states. Second important aspect leading to the relevance of this topic is the intensity public perception of this issue which to large extent eliminates the difference between tax avoidance and illegal tax evasion. The thesis generally focuses on transfer pricing in European context created by the activities of OECD reflected by EU legislation. The analysis shows that the OECD document on the issue are very beneficial instruments and their use is in many cases unified by the EU, which analyzes the...
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Tax avoidance and Credit Rating association
Orlova, Daria ; Watrin, Christoph (advisor) ; Molín, Jan (referee)
In this research, I present the analysis of the relationship between credit rating and tax avoidance. I found out that the lower the cash effective tax rate the stronger the association with credit rating. Sensitivity analysis showed that the probability of falling into more favorable credit rating category is increases and the probability of falling into less favorable category decreases if cash effective tax rate increases at least by 1%. Also, the negative association between book-tax differences and credit rating found.
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¨Tax aspects of the chosen company
Žemličková, Tereza ; Finardi, Savina (advisor) ; Vančurová, Alena (referee)
Bachelor´s thesis Tax aspects of the chosen company is focused on tax payment of company Agroles s. r. o. In the first part, I describe a company, its economic situation through economic and financial analysis. Another part is focused on the tax payment of company, which I will describe in the subsection taxes and tax payment of company during the period 2013-2015. The last part I will focused on tax avoidance, which I describe optimization and I try to propose another one.
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