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Analysis of applicability and transferability of the corporation tax losses within the EU
 Fuksová, Barbara ; Říhová, Lucie (advisor) ; Vančurová, Alena (referee)
This thesis analyses the treatment of tax losses in the Czech Republic in national and cross-border situations in the context of the recommendations of the European Commission and trends in treatment of losses, based on the cases of the European Court of Justice. Lack of immediate relief for losses leads to asymmetry of taxation, which is one of the causes of limitation functioning of the EU internal market. The comparison with other EU Member States based Czech Republic as a country with below-average possibilities of obtaining relief for losses. These include the 8 Member States have not yet adopted any national system of group taxation. Ways to get immediate relief for losses in domestic situations, including remains fiscally transparent entities in the group structure. Cross-border loss relief is available only if doing business in certain countries either by means of transparent entities or permanent establishments. This method of obtaining relief for losses is contrary to the interpretation of freedom of establishment, according to which there should be no discrimination on the basis of the legal form of business.
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Applicability and carry-over of tax losses, compared with the rules of the selected EU countries.
 Fuksová, Barbara ; Říhová, Lucie (advisor) ; Vančurová, Alena (referee)
The aim of this bachelor thesis is to capture the development of legal regulations of a deduction of tax losses and its practical application and to compare the current legislation in the Czech Republic with the selected countries of the European Union. The thesis has character of qualitative research. The first three chapters contain descriptive research, which draws primarily from the legislative sources. The last part includes comparative analysis based on the information from Ernst &Young about the corporate taxation in the EU. The comparison shows that the Czech Republic with its terms does not significantly differ from the rest of the EU. Conditions for the deduction of the tax losses in individual countries are various but we can find their common features. Almost all member states have certain restrictive conditions, which are designed to prevent abuse of the deduction of the tax losses in the economically unjustified cases. Individual circumstances vary only in the form but their purpose is identical. The comparison also shows that there are elements that may limit the overuse of the deduction of the tax losses and stabilize the revenue of the public budgets. But the Czech Republic does not use these elements.
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3 Fuksová, Barbora
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