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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 Optimization of Associated Enterprises
Šebková, Lenka ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
This diploma thesis is focused on international tax planning and tax optimization of relaties parties. In the first part of the thesis are written theoretical bases, which are important for understanding the whole work. In the analytical parts are stated the factors that are decisive for international tax planning. At the end of the work is presented the process of international tax planning and tax optimization on a specific subject.
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Odhad přesunu zisků po zavedení pravidel GloBE
Chrástová, Leona
The diploma thesis deals with the estimation of profit shifting after the in-troduction of GloBE rules. These rules, issued by the OECD, should ensure fairer taxation of the income of multinational companies and reduce base erosion and profit shifting. The aim of this work was to determinate changes in taxation of multinational corporations after the introduction of new rules for international taxation. To achieve the goal, the procedures described in Pillar 2 were applied to data from the Orbis database in the empirical part of this work. The empirical part also considered two assumptions for the collection of top-up tax, i.e. collection at the level of the jurisdiction of headquarter parent company and collection at the level of the jurisdiction of member entities. The results show that the OECD and EU jurisdictions could receive up to EUR 270 billion from this initiative. Large econo-mies such as the United States of America and Great Britain would receive the highest returns from this initiative. However, the largest percentage changes in tax revenues would be achieved by states known as tax havens, i.e. Luxembourg, Ireland and Latvia.
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Globální minimální efektivní korporátní daň
Hustáková, Klára
The objective of the bachelor thesis "Global Minimum Effective Corporate Tax" is to determine the impact of the introduction of a minimum effective corporate tax for selected groups of multinational enterprises based in the EU, in particular in relation to the impact on selected tax-related indicators. The bachelor thesis fo-cuses on the current and evolving issue of global taxation of multinational enter-prises. The theoretical part defines the concepts related to international taxation and multinational enterprises. Furthermore, the thesis examines in detail the OECD proposal and its two pillars. The practical part utilizes the findings from the previous sections to calculate the top-up tax for a group of companies based in the EU. The thesis argues that the current system of corporate taxation is outdated, and that the BEPS project represents a significant change in international taxation. The aim of the BEPS project is to increase transparency, reduce tax competition and promote fair taxation of multinational enterprises.
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International and intranational aspects of the double taxation
Chonka, Ivan ; Kotáb, Petr (advisor) ; Vybíral, Roman (referee)
International and intranational aspects of the double taxation Abstract This diploma thesis describes history (the recent one at least) of the need to regulate the taxation of international entities operating in more than one tax jurisdiction, its origins and the early efforts to create tax treaties preventing double taxation and the history of first internationally operating companies. It also compares tax treaties concluded between Czech Republic, Liechtenstein and Ireland, because there is a long-time gap between ratification of each of them, and thus we can observe, how did the Czech base tax treaty model change for this specific type of treaties during those years. The diploma thesis also summarizes differences between the treaties, provides a wider context regarding their basis, describes the specifics of Czech base model and evaluates the distinctions from the model treaties. Finally, the diploma thesis elaborates on the overall state of international taxation and especially in the Czech Republic, particularly in relation to its membership in European Union, in the BEPS initiative within the OECD (and Czech participation in it), and assesses Czech Republic's current condition regarding the economic state of the country, its most important trading partners and the challenges arising from the...
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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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What Drives the Location of Profits: Examining the Behavior of Multinational Enterprises from Country-by-Country Reporting
Boukal, Tomáš ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
Multinational enterprises (MNEs) are increasingly using offshore financial centers to pay lower taxes on their profits. This behavior has distortive effects on the global economy, as the concentration of MNE activities resembles the global map of taxation. In this thesis, I exploit the OECD country-by-country reporting statistics to analyze the determinants behind the location of profits. I employ a gravity model and demonstrate that profits are highly sensitive to geographical proximity, with both physical and societal distance being significant factors. Furthermore, my findings suggest that, first, the existing literature's definition of financial secrecy lacks a conclusive role in attraction of extra profits, as its effects are likely to be already conveyed through taxation. Second, regarding the profits specifically located in offshore jurisdictions, a reverse gravity relationship exists, where multinationals are willing to incur extra costs to shift profits to more distant tax havens, revealing yet another geographical aspect of taxation.
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Global distribution of revenue loss from corporate tax avoidance
Richtárová, Marie Anna ; Janský, Petr (advisor) ; Dubinina, Evgeniya (referee)
Existing empirical results suggest inequality of the global distribution of tax revenue loss resulting from tax avoidance techniques as base erosion and profit shifting to the detriment of developing countries. International Mon- etary Fund researchers conducted a pioneering study in this field in 2016 and introduced an innovative methodology to quantify the revenue impact. The aim of this thesis is firstly to re-estimate their model. Moreover, among other changes in the data, we exploit high-quality revenue data from the International Centre for Tax and Development-World Institute for Develop- ment Economics Research Government Revenue Database with an extended time range offering so more recent and accurate estimates of global revenue loss. Our findings suggest a slightly lower estimate of US$550 billion revenue loss globally. In terms of percent of the gross domestic product, the results indicate a less severe revenue loss compared to previous estimates. Follow- ing a previous re-estimation carried out by Cobham and Janský in 2018, we present updated loss estimates disaggregated for country income groups and regions. The results present further evidence of greater severity of rev- enue loss due to tax avoidance in low and lower-middle income countries in Sub-Saharan Africa, Latin America & the...
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International Tax Planning and Optimisation
Večeřová, Tereza ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
This diploma thesis deals with the issue of international tax planning and tax optimization. Based on the acquired theoretical knowledge, the key factors that are identified should be relevant for business entities within the framework of international tax planning. The following methods which are mentioned can be used in international tax optimization. The work concludes with a proposal for the implementation of international tax planning and corporate income tax optimization on a model example.
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