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Fight against tax evasion
Belková, Martina ; Vondráčková, Pavlína (advisor) ; Novotný, Petr (referee)
Name of the thesis: Fight against tax evasion Fight against tax evasion has become an all-society and mainly international problem. The task of this thesis is to approach the issue of tax evasion and give analysis of current legislation and measures combating the perpetration of tax evasion in the Czech Republic and abroad. This thesis seeks, inter alia, to describe how the international community, including the Czech Republic, handles with increasingly complex issue of tax evasion and to evaluate effective but also intended measures and their actual importance in connection with fight against tax evasion. The thesis is in addition to introduction and conclusion divided into four chapters. The first chapter of the thesis describes the basic definitions related to taxes and tax system in general. The second chapter deals with the term tax evasion, the causes of its occurrence and its consequences. This chapter also defines the terms closely related to tax evasion, i.e. tax havens and grey economy. The third chapter presents different types of tax evasion in the Czech Republic, with a deeper analysis of value added tax, consumption tax and income tax. The fourth chapter is the most important part of the thesis. It deals with measures taken in order to combat tax evasion in the USA, Organization for...
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Determinants of the Demand for Tax Haven Operations: Empirical Evidence from the Czech Republic
Burianová, Markéta ; Janský, Petr (advisor) ; Švarcová, Natálie (referee)
The aim of this thesis is to explore the firm-specific determinants of the demand for tax haven operations by Czech firms. Our objective is to better understand the firms' incentives for tax haven use, and furthermore whether there exists cross-haven heterogeneity in those incentives. The thesis examines the firms' tax haven investment behaviour by analysing firm-level data for 15,530 Czech firms for year 2013. To the extent of our knowledge, this has been the first research of its kind devoted to Czech firms. The evidence suggests that larger, more profitable firms with larger international presence are most likely to use tax havens. The analysis also indicates that higher firm indebtedness is associated with greater likelihood of establishing tax haven operations. This would suggest Czech firms engage in profit shifting through the use of debt financing. Furthermore, service firms were found to be more likely to use tax havens than manufacturing firms. This contrasts with previous research where R&D intensity was a leading indicator of tax haven use. Additionally, we found significant cross-haven heterogeneity in the determinants, particularly in the sector-specific characteristics. In our sample, service firms favoured Cyprus and the Netherlands, while manufacturing firms preferred Luxembourg...
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International Aspects of Taxation in the Czech Republic
Kotáb, Petr ; Bakeš, Milan (advisor) ; Karfíková, Marie (referee) ; Dřevínek, Karel (referee)
JUDr. Petr Kotáb International Aspects of Taxation in the Czech Republic SUMMARY Economic life of the current period is marked by high level of globalization of the economy and ever growing volume of cross-border flows of labor, goods, services and capital. In this situation, issues of international taxation affect not only sporadic cross-border transactions of selected types of subjects but virtually daily tax relations of large numbers of tax subjects, legal entities and individuals. Principles and regularities of international taxation are spreading in an ever growing extent into the intrastate level and are influencing the production of tax laws and everyday application practice of tax administrators. International aspects of taxation project into intrastate tax relations when there is a certain foreign element present in the tax relation. Such foreign element can show on the level of the subject of a tax relation (e.g. a non-resident taxpayer, permanent establishment, etc.), or the object (e.g. foreign-sourced income), or as the case may be, the tax relation content (e.g. tax liability imposed by a foreign state and the necessity to reflect it in the inland for the purposes of prevention of double taxation, e.g. by a credit method). A foreign element in the tax relation usually indicates the danger of...
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Legislating against Tax Avoidance
Kamínková, Petra ; Boháč, Radim (advisor) ; Kohajda, Michael (referee)
Kamínková, Petra: Legislating against Tax Avoidance Abstract Tax avoidance practices of multinational corporations have recently come under criticism by governments and general public. In my thesis, I analyze various methods states may use to fight such behavior, with special regard given to the Czech Republic. In the first chapter, I introduce basic principles of international taxation. Second chapter focuses on several commonly used methods of avoiding taxes, and the tools used by governments to fight particular types of undesirable transactions and set-ups (Targeted Anti-Avoidance Rules - TAARs). The analysis therein suggests that these tools may be successful to a degree, but may never cover all possible scenarios. Third chapter elaborates on judicial doctrines and General Anti-Avoidance Rules (GAARs). These tools attempt to address tax avoidance methods not anticipated by legislature. My contention is that while these concepts may be quite powerful, they may also gravely threaten legal certainty. Therefore, I conclude that they should be used sparingly. Final chapter presents a set of auxiliary tools that may improve the communication between tax payers and tax authorities, thus helping the states to gather information faster and more efficiently, allowing them to react to arising issues with minimal...
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Don't pay taxes, save your money!
Bradáč, Michal ; Kemény, Irena (advisor) ; Gregor, Martin (referee)
Bachelor thesis "Don't Pay Taxes, Save Your Money!" focuses on the impact of the existence of tax havens on private and public sector. On the theoretical level, it shows the attractivity of tax havens for sufficiently large firms that can afford to pay costs of tax planning and profit manipulations. On the empirical level, it shows that tax havens are really the most successful jurisdictions in attracting foreign investors. In the end, two models of tax competition are introduced in order to describe the importance of tax competition for the whole economy. Keywords:Tax Haven, Tax Avoidance, Tax Competition
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Analysis of specific instruments applied in the financial management of TNC with a focus on transfer pricing
Baluchová, Daniela ; Taušer, Josef (advisor) ; Sato, Alexej (referee) ; Baláž, Peter (referee)
Transfer pricing plays a crucial role in the financial management of TNC as it significantly influences revenues and costs allocation among affiliates of TNC that are located in countries with different tax regimes, interest rates, political situation and economic environment. Recently, transfer pricing is scrutinized in respect of tax minimisation strategies adopted by TNC which raises various conflicts of interest with tax authorities in some countries of their presence. The main objective of the dissertation thesis is to provide a comprehensive empirical study on international transfer pricing in the Czech Republic from the perspectives of both taxpayer and the tax authority. With regard to the complexity of transfer pricing, manufacturing afiliates of TNC located in the Czech Republic were selected to be examined in more detail. The thesis is structured into five chapters. The first chapter defines theoretical framework based on which the analytical part of the thesis is elaborated. The strategies applied by TNC in setting transfer prices are strongly affected by the transfer pricing regulation and interpretative experience of the particular countries in which they operate. In this context, the Czech transfer pricing legislation as well as selected case law is analyzed in the second chapter. Given the complexity of the issue of transfer pricing, the third chapter deals with selected aspects that are considered critical when setting transfer prices. The fourth chapter presents key findings regarding transfer pricing strategies applied by TNC located in the Czech Republic to transfer pricing issues. The fifth chapter summarizes the approach of the Czech tax authorities to the transfer pricing audits and at the same time evaluates related risks borne for taxpayers in this respect. The thesis reveals that manufacturing afiliates of TNC located in the Czech Republic generally prefer non market (cost based) transfer pricing methods when setting transfer prices, whereby there are several factors influencing their decision making, out of which internal economic conditions and foreign exchange risk management are deemed the most important factors, while tax optimisation as well as restrictions on profit repatriation are considered relatively less important factors. The study further indicates certain inconsistency between declared functional and risk profiles and decision making competences. In this connection, it was found out that the Czech afiliates in which the foreign parent company is involved in transfer pricing set-up incur tax losses. In response to the increasing importance of transfer pricing and international initiative Action Plan BEPS (Base Erosion and Profit Shifting) it can be stated that the approach of the Czech tax authorities has become more intensified and sophisticated. The Czech tax authorities challenge declared and actual functional and risk profile of taxpayers as well as economic substance of realized intercompany transactions. Furthermore, number of transfer pricing audits has increased and become targeted on risky taxpayers such as companies granting investment incentives or incurring tax losses etc. As a result, additional tax assessment due to incorrect transfer pricing significantly increases over recent years.
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Tax Havens and their Utilization
Malý, Zdeněk ; Dubový, Roman (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis describes the topic of tax havens and their usage. Further it describes issues of international tax planning. The thesis is divided into three parts. The first one, theoretical, explains basic concepts of this issue. Analytical part follows with description of present state of taxation in selected countries. The last section of this thesis shows some uses of tax havens and whether or not it offers tax advantages.
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Tax Heavens from Czech Republic Perspective
Zeman, David ; Hodinková, Monika (referee) ; Kopřiva, Jan (advisor)
In the theoretical part this work deals with the concept of tax havens, their distribution, use and selection. The second part compares three companies in the Czech Republic with a turnover of hundreds of thousands to several millions, and it demonstrates which for them would be advantageous or disadvantageous - to operate in the tax haven compared to staying in the Czech Republic.
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Analysis of Tax Havens in International Tax Planning
Bolf, David ; Klusáčková, Veronika (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis deals with the analysis of Tax Havens in the International Tax Planning. The thesis is divided into four parts. The first part is concerned with the internation tax planning. In the second part, the term tax havens is clarified together with the dilema of the bank secrecy, and the situation accrording to the fight against tax havens. The third part dedicates and analyses the tax havens in a detail view. The last part aims to analyse data and sorts tax havens into the categories by potentionallities of usage.
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