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Demonstration of compliance with substantive legal conditions entitlement to VAT deduction in the NSS jurisprudence
Rambousek, Petr ; Boháč, Radim (advisor) ; Tuláček, Michal (referee)
v anglickém jazyce The aim of the thesis is to gain an insight into the Supreme Administrative Court's decision- making in disputes concerning the mutual position of tax subjects and tax administrators in tax proceedings when proving the right to VAT deduction. The method of the thesis is a content analysis of selected judgments of the Supreme Administrative Court. The thesis is divided into. The first three parts of the thesis serve primarily to introduce the reader to the issue and its specifics. In the next 5 parts, the expected inequality in the position of tax subjects against the tax administrator is gradually examined. The centre of gravity of the thesis is found in Part 5, which identifies the construction of the procedure for the removal of doubts as the main source of the impermissible inequality of position of the subjects in the tax proceedings. Parts 6 to 8 then deal with the sub-aspects of the unequal position and highlight the consequences of the construction of the procedure for the removal of doubts, which requires a very low level of evidential certainty for its functionality. While these sub-conclusions are not particularly problematic in isolation, taken together they create an untenable situation of unequal burden of proof between the tax authorities and the taxpayer. The...
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Methodology for Setting a Transfer Price between Associated Enterprises
Trögnerová, Martina ; Pecinová, Jana (referee) ; Brychta, Karel (advisor)
Master thesis deals with the issue of international taxation of transfer prices between related parties. Diploma thesis defines the basic theoretical concepts of transfer pricing with a focus on international and domestic law. The analytical part of the thesis is devoted to the analysis of the case law, the subject of which is transfer pricing. The practical part is based on acquired knowledge to elaborate a methodological tool to transfer pricing. The present findings are applied to a model example.
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The tax audit from the perspective of the fundamental tax administration principles
Špírková, Taťána ; Marková, Hana (advisor) ; Kohajda, Michael (referee) ; Radvan, Michal (referee)
The tax audit can be defined as one of the practices of the tax authorities modified by Act No. 280/2009 Coll., the Tax Code. The aim of the tax audit corresponds with the basic aim of the tax administration, which is primarily to establish correctly a tax assessment. This dissertation is focused on the tax audit from the perspective of the fundamental tax administration principles. The presented dissertation is divided into nine chapters, most of which are further subdivided. The first chapter is focused on the determination of the tax audit. In the second chapter, the attention is paid to the constitutional principles controlling the tax audit, mainly to selected regulations of the Constitution and the Charter of Fundamental Rights and Freedoms. The following third chapter is focused on the isuue of good governance principles. The fourth chapter deals with the fundamental principles of tax administration, as expressed in the Tax Code in §5 - §9. These principles are specified as a basis for the next part of the work. Chapters five to eight are dedicated to the tax audit, which is divided into the beginning of the tax audit, the tax rights and responsibilities during the tax audit, the progress of the tax audit and the final chapter is focused on completion of the tax audit. The last chapter is...
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Some aspects tax control
Peláková, Andrea ; Boháč, Radim (advisor) ; Marková, Hana (referee)
My dissertation deals with some aspects which are connected with tax kontrol. The main point of my paper is to give a detailed description od selected aspects nad to compare thme according to an old and a new version of legal acjustment. An introductory chapter pays attention to defining tax control. Following chapters deals with the opening of tax kontrol, repeated tax kontrol, periods for tax setting, kontrol report and means of protection dutiny the tax control. My own practical experience with tax kontrol is written about in the last chapter.
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Tax audit
Amrich, Peter ; Boháč, Radim (advisor) ; Marková, Hana (referee)
The aim of my thesis is the evaluation of tax audit issues and eventually to propose changes de lege ferendae. At the same time I apply the principles of tax audit in its selected aspects. The main aim of the thesis - a complex evaluation of the tax audit - achieved through partial commentaries and evaluations, which are reflected in the titles of each chapter and by using scientific methods such as descriptive method, the method of deduction and applications, as well as the synthesis method and the method of subjective criticism. The logical structure of my thesis is accurately represented by the structure of its seven chapters and several subchapters and its names. In the first chapter I discuss the institute of tax audit in general. In the second chapter I discuss the principles that need to be applied to institute of tax audit. The third chapter deals with stages of tax audits. The fourth chapter is reserved to protection during and after tax audit. Criminal context of tax audit is discussed in fifth chapter. Statistics of tax audit and my conclusions deducted from the statistic data are focused in the sixth chapter. The case law on the tax audit is focused in the seventh chapter. Processing of each chapter is accompanied by my subjective evaluations of individual aspects of the tax audit,...
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Tax audit
Václavík, Petr ; Karfíková, Marie (advisor) ; Kohajda, Michael (referee)
59 Tax Search - English summary The aim of this work is to describe the basics of tax search of Czech tax authorities in view of new tax procedure act, and jurisdiction. In 2011 a new Tax Procedure Act has come into operation. It affects all tax procedures including tax search. It has established new principles of tax procedures, and has also included some jurisdiction. However, it has also established some new questions, that must be sold by new jurisdiction. Tax search is a specific procedure how government, using its special agencies - usually Tax Authority Offices, monitors declared taxes. Sometime tax authorities think their work is so important that there is no limitation in used tools. Then a court must say there is a limitation not only in act but also in principles of good administration. Some of these opinions were included into the new act, some were left intact since government does not agree with them. Tax search must have its goal. According to Constitutional Court a tax authority cannot start arbitrarily but there must be some suspicions, and a prove of it. Tax search alone can be separated into 3 parts - beginning, process, and conclusion. All these parts have their guidelines. Especially at the beginning tax authority can start tax search in given time of 3 years, and whole tax search must...
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Kreativní účetnictví z pohledu správce daně a auditora
Povolná, Tereza
Bachelor thesis deals with the issue of creative accounting and control by the tax administrator and auditor. The theoretical part is focused on the definition of the concepts of creative accounting, the errors in accounting, and deceptive conduct. The aim of this thesis is to compile a handbook for auditors and for the tax administrators to facilitate the detection of illegal practices in accounting, with a focus on the areas in which errors may most often be made. The survey from between the years 2011 and 2013 by Price Waterhouse Cooper, and also the survey by the company Skanska and Enron have been used to achieve the thesis aim because these companies have committed creative accounting in the past.
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Problematika daňové kontroly a specifika komunikace se správcem daně
Diviš, Jakub
The diploma thesis deals with issues of tax inspection and communication with the tax authority. The theoretical part of the diploma thesis defines the basic concepts needed to analyze the tax inspection. The second part of the diploma thesis includes an analysis of the tax inspection and the communication with the tax authority. Based on this analysis is identified the main problems in the tax administration, and afterward proposed solutions to the main problems.
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