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International double taxation
Körbl, Hugo ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
práce v anglickém jazyce International double taxation International taxation is a very large topic. It is possible to write hundreds of pages about this subject but there will still be many problems which will be waiting for their solution. This theme is also very interesting and in this time very actual. I am sure that importance of international taxation will be highly raising in the future. This is caused by high intensity of the mobility of people and corporations, capital, services, and property but on on the other side it is caused also by still higher and higher number of tax evasions. The states are then forced to make a larger effort in cooperation between them and also to try to prevent the tax evasions. Double taxation agreements should be considered as a good solution for prevention of tax evasions and also mainly only these treaties can assure fair distribution of paid taxes between the states. It wasn't possible to make comprehensive analysis of this large subject in this relatively short thesis. So I decided to focus only on some issues of international double taxation. I was trying to choose issues which make often problems in application or issues which I am considering as very interesting. Sometimes the work on my thesis was not easy because of high number of different opinions....
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Taxation of Foreigners
Zeman, Pavel ; Jaroš, Luboš (referee) ; Kopřiva, Jan (advisor)
The bachelor thesis deals with taxation of foreigners - residents and non-residents - in the Czech republic. It explains the differences between cooperation with the States of the European Union, contracting and non-contracting States. The main aim is definition of basic differences and finding the ways to optimize the tax liability of foreigners. Attention is also moving in specific cases that are resolved by the agreements for the avoidance of double taxation between the Czech Republic and Slovakia or the Czech Republic and France.
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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 Incomes arising from the Construction Contract realized in Slovakia
Minář, Michal ; Kučera, František (referee) ; Brychta, Karel (advisor)
This diploma thesis deals with the obligations for implementing the construction project in the Slovakia and its taxation. At first is defined basic terminology, concept of single market of the European Union and the harmonization process of direct and indirect taxation. In the analytical part of the thesis are relevant sources of international, union and national law analyzed. The practical part is focused on specification construction contract, accomplishment all obligations and an exemplary taxpayer's tax liability is calculated.
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Electronic Commerce with the U.S.
Pavlíček, Martin ; Dvořák, Jiří (referee) ; Dvořák, Jiří (advisor)
The content of the paper is to model new company in the American state, Nevada and its operation from the Czech Republic over the Internet. In this thesis is included theoretical resources, analytical section discusses the types of companies in the USA, the tax liability of companies related to the USA legislation and the final section proposes solution together with a cost calculation to establish a new company. And also which kind of services are used for doing business in the USA over the Internet.
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International cooperation in the fight against tax evasion in the field of direct taxation at the level of OECD and EU
Burešová, Lucie ; Finardi, Savina (advisor) ; Tecl, Jan (referee)
The thesis deals with international cooperation in the fight against tax evasion in the field of direct taxation at the level of OECD and EU. First, the thesis explains why international tax evasion occurs, what the most common forms of tax evasion are and also how multinational companies use international, sometimes even aggressive, tax planning to reduce the tax burden. The next section specifies diverse measures already adopted within the OECD and the EU and also those that are still in preparation. Any action taken at the international level is put into context with what the Czech Republic has already introduced. Mutual exchange of information between countries is one of the most important tools in the fight against tax evasion. That is why an analysis of spontaneous exchange of information and on request between CZ and other cooperating countries was carried out in the last part of the thesis. The analysis was carried out on the basis of publicly available data from Annual Reports of Financial Administration of the Czech Republic and also on the basis of data which were received from the Department of international tax cooperation - direct taxes of General Financial Directorate.
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APLICATION OF CONVENCION BETWEEN THE CZECH REPUBLIC AND THE REPUBLIC OF AUSTRIA FOR THE AVOIDANCE OF DOUBLE TAXATION
KREMEROVÁ, Eva
The aim of diploma thesis is to analyze realization of a Convention for the avoidance of double taxation between the Czech Republic and the Republic of Austria. The paper explains what the international double taxation is and describes the types and methods of its prevention. It describes difference between tax residents and tax nonresidents. Further it describes development of Conventions for the avoidance of double taxation between the Czech Republic and the Republic of Austria and compares the Convention No. 48/1979 and No. 31/2007 which were applied in mutual tax relations between both countries. The paper is mainly focused on the situation of Czech tax residents who receive incomes from employment in Austria and shows on practical examples how the situation developed from 2007 to present. It describes the complicated situation of taxpayers in 2008, when they first proceed according to a new Convention between both countries and explains the calculation of the "super-gross wage" when incomes are from employment abroad. The paper also describes the approach to Austrian taxation of interest payments and resolve procedure Czech taxpayers in these cases. Finally, this paper examines the attitudes of both countries to adhere to Convention for the avoidance of double taxation and describes the difficult situation of Czech taxpayers with incomes from Austria.
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The Taxation of Natural Persons Not Rezident on Territory of the Czech Republic
FALTÝNOVÁ, Jaroslava
This work provides a basic orientation in matters of taxation of non-residents - natural persons in the Czech Republic. At the beginning are explained the concepts, methods to avoid double taxation, and examines the various categories of income taxation of individuals and also affects the social and health insurance. In the practical part are a questions addressed to the specific practical examples, including file and completing tax return, social security and health insurance reports and other related forms. In conclusion are mentioned the news regarding the taxation of non-natural persons and author´s proposals. The work shows the possibility to limit tax evasion carry out the transition from the system of automatic oneself declaration to the tax international refund system. There are added also useful attachments.
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