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Analysis of Employing of Foreigners in the Czech Republic
Zemanová, Petra ; Ivánek, Lumír (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis focuses on the system of employing and taxation foreigners in the Czech Republic. Its aim is to explain the theoretical background of this issue, analyze the labor market situation and clarify the principle of taxation of foreigners. In the analytical part, this knowledge will be applied to individual cases and in the design part, for each taxpayer will be proposed a solution to reduce tax liability as much as possible.
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International Double Taxation
Vašíčková, Pavlína ; Fajkusová, Ivona (referee) ; Brychta, Karel (advisor)
This bachelor’s thesis deals with issue of international tax relations. It is about the general background of this area, i.e. about intranational tax law in connection with conventions on avoidance of double taxation, cooperation of international tax administration, includes also analysis of nowadays situation and the practical outcome that deals with taxation process.
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Taxation of Dividends of Czech Republic Tax Non-residents
Krčmová, Michaela ; Svirák, Pavel (referee) ; Brychta, Karel (advisor)
This bachelor thesis is concerned about taxation of dividends which are payed out from Czech Republic sources to tax non-residents – natural persons. Describes, analyzes and systematized domestic legislation and international agreements related to the focus of thesis. In the practical section the methodical procedure for the payment of profit shares, or advances on them, and their taxation, is determined on model cases. Emphasis is placed on the definition of differences depending on the state in which the owner of the income is tax resident.
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International Tax Planning and Optimization
Kopecká, Jana ; MBA, Kateřina Franková, (referee) ; Brychta, Karel (advisor)
The diploma thesis focused on international tax planning and tax optimization. The diploma thesis specifies what is an international tax planning and underlines its importance in these days. On theoretical knowlege the diploma thesis summarizes key factors that should entrepreneurs in international tax planning and optimization to take into account. End of the thesis presents proposal the progress of the process of international tax planning and also on the particular case.
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Taxation of Rental Incomes in the Czech Republic
Kasalová, Kristýna ; Poláchová, Jana (referee) ; Brychta, Karel (advisor)
This bachelor thesis addresses the international taxation of a selected income category. Namely, it concentrates on the taxation of income of tax residents and non-residents of the Czech Republic arising from the rent of immovable property in the Czech Republic. In regard to the focus of the thesis, there are presented model situations that illustrate the method of taxation and the use of methods of avoiding double taxation.
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International double taxation
Řezníčková, Markéta ; Kotáb, Petr (advisor) ; Sejkora, Tomáš (referee)
This diploma thesis deals with some questions of the international double taxation, particularly with the basic terminology and principles of the international taxation, bilateral double taxation treaties and new tools of legal regulation of the international double taxation such as BEPS, MLI, a package of European directions called Anti-BEPS and its implementation into the Czech law. The aim of this thesis is to identify, describe and analyse sectional questions in respect to long-term and current evolution. In the introduction I briefly introduce the topic. Afterwards the thesis is divided into four chapters that are linked to each other. The first chapter presents to the reader basic terminology and explains basic principles of this field independently and in relation to current legal regulation. Further I describe the types of double taxation and other institutes related to the international double taxation such as international double non-taxation. The second chapter deals with means of elimination of the international double taxation. Two basic methods are described and some of them are represented by basic examples. There are also described means of elimination of the international double taxation that can only be used in tax treaties (not in the national law). The last subchapter describes...
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Double taxation avoidance treaties
Dík, Lukáš ; Karfíková, Marie (advisor) ; Vybíral, Roman (referee)
Treaties for the avoidance of double taxation This thesis deals with treaties for the avoidance of double taxation, which initially gives a general definition of taxation, then the essential elements of treaties for the avoidance of double taxation and based on the analysis and comparison draws conclusions. The thesis aims to give a comprehensive overview of the issues concluding treaties for the avoidance of double taxation and show what influence they can have on individual provisions of the cross-border effects of economic entities. I start from the hypothesis that the actual provisions of individual contracts can affect decision-making bodies, whether in the country to do business or not. In conclusion, this hypothesis is confirmed. The first chapter of this thesis deals with the taxation generally. Formulates double taxation in general, the various essential elements of taxation as subject to tax, the tax rate. It also deals with the sources of the Czech tax law, the emergence of double taxation and the method of its solution. This chapter also deals with tax crimes, i.e. tax havens, manipulation of transfer prices and freight handling. The second chapter focuses on agreements on avoidance of double taxation. It describes the OECD model treaty, the UN, including their development and highlights...
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International double taxation
Topinka, Lukáš ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
- International double taxation The purpose of this thesis is to describe basic terms, history and importance of double taxation agreements and it also describes European law of double taxation. This thesis is composed of five chapters. Chapter one is an introductory part and describes importance of elimination of international double taxation. Following parts describes structure of this thesis, aim of this thesis and used methods. The second chapter deals with basic terms of double taxation, general meaning of double taxation, tax legislation in Czech Republic and EU law concerning taxation. In following parts, it defines the term of double taxation, both intra national and international and its types. The third part describes the methods of elimination of double taxation, exemption and credit. The fourth part of describes limited and unlimited tax liability. The fifth part deals with tax residents and non-residents, the sixth part deals with transfer pricing. The seventh part discusses tax havens. The last, eight, part is concerned with transparent entities. The third chapter analyzes the international double taxation treaties, their history, importance and basic principles. In following parts, it describes types of these agreements, and in the last part, it describes the provisions of model...
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