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Double Taxation Treaties and their Influence on Business Activity
Tuláčková, Anna ; Černohlávková, Eva (advisor) ; Smrčková, Michaela (referee)
The thesis is focused on international double taxation and its implications for international business activity. At first, it focuses on double taxation definition, the reasons of its occurrence and its impacts. The next part deals with bilateral double taxation treaties and their principles, including a comparison of Model conventions developed by the OECD and the UN. The last chapter focuses on the areas of transnational corporations activity that are most impacted by tax matters, such as the form of their presence in the foreign market, transfer pricing and international labour hire. The basic principles of international tax planning are explained as well.
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Tax planning in corporation
Nevodnicheva, Yulia ; Kislingerová, Eva (advisor) ; Dvořáček, Jiří (referee)
This thesis "Tax planning in corporation" puts brain to legal entity income tax and it is looking for possible solutions in tax planning in corporation. The first part deals with the tax theory, the other part is the theory of tax planning, comparison of tax regimes and tax policy and tax revenue by optimizing both internationally and in the local aspect. The last part discusses options for optimizing tax
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Possibilities of international tax planning for selected countries
Jauker, Michal ; Vítek, Leoš (advisor) ; Mareš, Milan (referee)
This thesis puts brain to possibilities offered to companies with domicile in the Czech Republic via international tax planning, lawful usage of these possibilities for tax liability optimization and increase of company profits. Major part of the thesis is dedicated to theoretical ways of international tax planning utilization for selected model. Cyprus, Ireland and Netherlands are included among main surveyed countries. There are described ways how can be reduced most effectively the tax liability of selected active and passive incomes.
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Transfer-pricing-based tax planning
Lhotský, Vladimír ; Buus, Tomáš (advisor) ; Kuncl, Karel (referee)
This work brings a systematic approach to the design of a transaction-based transfer-pricing policy of a multinational group and related tax optimization. The foundation of the work is a description and analysis of all aspect of the transfer-pricing regulation including a detailed classification of particular business risks. Using a certain simplification of the complicated relations in multinational groups, a system compliant with transfer-pricing rules is designed, hence minimizing the tax risk. Further, I devote my attention to rather complicated areas of transfer-pricing like pricing of payments for intangible property, pricing in non-standard structures and allocation of exchange rate risk. After the build-up of the architecture of the transfer-pricing system, analysis of the tax optimization possibilities adhering to all regulatory requirements is carried out. The detailed description of the tax effective supply chain management planning concept and other planning instruments is presented. The final part is devoted to the negative tax implications of business restructuring steps analyzed on the examples of particular structures.
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Analysis of case law from the perspective of abuse or circumvention of the tax law
Růžičková, Tereza ; Kubátová, Květa (advisor) ; Schvábová, Andrea (referee)
Everyone seeks to minimize his tax liability. Generally, we can say that reducing the tax burden takes several forms. In this diploma thesis I deal with specific area - "tax avoidance", which is properly defined in the first chapter. Analysis and subsequent synthesis of the jurisprudence of the Supreme Administrative Court evaluates the current state of interpretation and usefulness of individual instruments by the tax authorities "correct" avoidant behavior of taxpayers. Interpretation of Czech courts is supplemented by a specific key court decisions of the European Court of Justice, defining the rules of one particular instrument. Finally, a Czech tax policy recommendation on the need for adaptation and mainly the general principle against tax avoidance in the Czech tax law could be found at the end of this thesis.
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