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Taxation of Non-residents Incomes
Hofmann, Eduard ; Lněnička, Libor (referee) ; Brychta, Karel (advisor)
The bachelor thesis deals with the income taxation of non-residents in the Czech Republic. Its concern are physical persons who are taxed by a withholding tax. The main aim of this bachelor theses is to approach the problems of international double taxation and to demonstrate fiscal steps leading to tax optimization of non-residents for selected type of income.
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Taxation of Chosen Set of Taxpayers
Jandová, Zuzana ; Václavíčková, Pavla (referee) ; Brychta, Karel (advisor)
This bachelor thesis deals with taxation of student´s incomes. It analyzes the impacts of so-called tax reform in the regard of personal income tax with effect from 1. January 2008, it targets also the years 2007, 2008 and 2009. My bachelor thesis includes instructions, procedures, practical examples and necessary information for understanding the system of taxation of incomes of physical persons and the correct process of personal income-tax return. Target of this thesis is to optimise tax liability of students by finding the optimal variant of taxation when criteria are given. Student´s social and health insruance problems are also included in this work.
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HARMONIZATION OF TAXATION OF CORPORATIONS IN THE EU
Skalická, Hana ; Sadovský, Zdeněk (advisor)
After accession to the European Union, tax issues acquired and are still acquiring an entirely new character. A new legal environment is forming both in the Czech Republic and in the European Union. Until now, only indirect taxes have been harmonised, with direct taxes having remained in the domain of each member state. However, we are now feeling pressure to harmonise this area as well. Cases concerning value added tax belong to those that are now most often being resolved in front of the European Court of Justice in Luxembourg. Cases regarding direct taxes are also becoming increasingly important. Will direct taxes be harmonized to the same extent as indirect taxes have? When potential investor is considering his investment into a company, he needs to match comparable figures. Definitely, one of the most important criterions is the amount of profit after taxation followed by payout of dividends. If there are different ways of taxation of corporations in various EU Member States, then there would be no possibility to compare corporations placed in various EU Member States objectively. Therefore, the aim of this thesis is, based on the research in the whole EU regarding taxation of corporations, to suggest a method how to harmonize taxation of corporations, which now prevents companies from trading in a single EU market, and also to minimize corporation’s costs of fulfilment of tax administration requirements of each Member State. This aim has been achieved through the following partial aims: .. An analysis of taxation of corporations in each of all 27 EU Member States, .. An analysis of proposals of the European Commission regarding harmonisation of taxation of companies, .. Suggestion of own method of harmonization of taxation of corporations in the EU. In conclusion, there are emphasized the contributions of this thesis to the science, to the practice and to education.
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International Tax Optimization
Pavliska, Petr ; Havířová, Barbora (referee) ; Brychta, Karel (advisor)
This thesis deals with ICE - industrial services as The company must pay a withholding tax on their invoices received. Economic activity is undertaken in Germany. Company income from the supply of goods and services. Selected issue will be resolved by the formation of a permanent establishment or establishing a subsidiary in Germany. Developed solution provides the possibility of effective expansion into foreign markets. Results of the work allows the company to decide which option is best for her.
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FATCA (Foreign Account Tax Compliance Act)
Lojíková, Andrea ; Finardi, Savina (advisor) ; Vančurová, Alena (referee)
This bachelor's work is about FATCA (Foreign Accoun Tax Compliance Act), which is a new american taxation law, which was oficially signed, by United States of America, into law on March 2010 to confine tax evasion. My main aim was to define how FATCA works, clarity about strategy, the challenge of customer identification and what FATCA is all about. There are aslo defined some payments of foreign financial institutions and rules for withholding agents.
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Taxation of permanent establishments
Stehno, Pavel ; Vančurová, Alena (advisor) ; Jelínek, Michal (referee)
Taxation of permanent establishments is one of the most complicated areas within international tax law. The system of permanent establishment is based not only on the national legislations of relevant states, but also (mainly) on the international double taxation treaties. This diploma thesis analyses those issues in the taxation of permanent establishments, which are the most up-to-date or can be considered as the key questions of the whole concept and therefore can be significant for the future development of the permanent establishments. However the technically perfect system of permanent establishments should come hand in hand with the practical feasibility and overall efficiency. This assumption is nowadays challenged by several trends like the growing popularity of offshore tax heavens or the development of information technologies, which complicate the determination of (fixed) place of business through which the business of an enterprise is wholy or partly carried on. The technical analyses in this thesis are, therefore, supplemented by the objective evaluations from the perspective of valid legislation, possible approaches of the tax authorities, as well as of the enterprise considerations and also the global international taxation picture. This involves also the aspects of tax policies at the level of sovereign states, especially the Czech Republic.
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