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Harmonisation of corporate income tax from the perspective of European law
Houlík, Jan ; Vondráčková, Aneta (advisor) ; Tomášek, Michal (referee)
Harmonisation of corporate income tax from the perspective of European law Abstract The aim of this thesis is to analyse how successful is a fight against aggressive tax planning, tax avoidance, and abuse of law in the area of the corporate income tax harmonisation within the European Union. Even though the primary goal of harmonisation in the area of direct taxation was to ensure the proper functioning of the internal market, recently, as a reaction on various scandals and affairs of big multinational enterprises in connection with lowering their tax burdens and also as a reaction on the BEPS project created by the OECD, one of the primary goals of tax harmonisation is becoming the fight against aggressive tax planning. In this thesis is firstly analysed the effort of the European Union consisting of harmonisation using legislative instruments, in particular, directives in the area of corporate income tax, including its gradual development. Specifically, the Parent- Subsidiary Directive, the Merger Directive, the Interests and Royalties Directive, and the Anti-Tax Avoidance Directive are taken into account. The fight against aggressive tax planning, tax avoidance, and abuse of law, in particular abuse of benefits resulting from the directives is stressed in this context. Further, a case-law of the Court of...
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