|
|
International double taxation of corporate income
Vybíral, Roman ; Karfíková, Marie (advisor) ; Boháč, Radim (referee) ; Papoušková, Zdenka (referee)
International tax law forms in an increasingly globalized world a significant regulator applying to constantly expanding group of entities whose activities are not exclusively tied to the area of one country. On the contrary, due to the continuously increasing link between national economies these entities very often simultaneously operate across multiple territories which often results to not always clearly identifiable tax law implications. It may be noted that international cooperation between states got over long decades to the fairly high level, especially in terms of prevention of the negative effects of double taxation of income to the subject to income tax. These negative effects were seen, and indeed even today sometimes may be seen in the form of increased tax burden of tax subjects, which is related to unwillingness to cross-border activity. Also especially developed countries very often aim to support such cross-border activities due to a positive impact into their public budgets. On the other hand, it is still possible to see certain gaps which, if used appropriate by the tax entities open the way to circumvention of rules and general principles on which international cooperation on these issues is based. These problems are primarily based on the concept of tax sovereignty which...
|
|
|
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...
|
|
|
The tax system and agreements on the avoidance of double taxation
Kohoutová, Petra ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
1 Abstract: The tax system and agreements on the avoidance of double taxation This diploma thesis "The tax system and agreements on the avoidance of double taxation" is focused on practical issues in the field of using international corporate structure in order to decrease the tax liability applicable on entrepreneurs. The diploma thesis includes the basic description of the legal rules applicable in the Czech Republic, such as acts and also international treaties. In the field of EU law, the diploma thesis described briefly EU directives based on which it is possible to transfer dividends, interest and royalties between mother and daughter companies without withholding tax payable in the Czech Republic. International treaties described in this diploma thesis were double taxation avoidance treaties between the Czech Republic and Cyprus and between Cyprus and Seychelles. First part of the diploma thesis is describing legal regulation of income taxes applicable in the Czech Republic. It is aimed mainly on interests, dividends and royalties. The first part of the diploma thesis is of theoretical nature which gives basics for the second and third part which practically analyze possibilities to decrease tax burdens of entrepreneurs. Second part of the diploma thesis brings analysis of individual model situations...
|
|
|
Analysis of Employing of Foreigners in the Czech Republic
Zemanová, Petra ; Ivánek, Lumír (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis focuses on the system of employing and taxation foreigners in the Czech Republic. Its aim is to explain the theoretical background of this issue, analyze the labor market situation and clarify the principle of taxation of foreigners. In the analytical part, this knowledge will be applied to individual cases and in the design part, for each taxpayer will be proposed a solution to reduce tax liability as much as possible.
|
|
|
International double taxation
Topinka, Lukáš ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
- International double taxation The purpose of this thesis is to describe basic terms, history and importance of double taxation agreements and it also describes European law of double taxation. This thesis is composed of five chapters. Chapter one is an introductory part and describes importance of elimination of international double taxation. Following parts describes structure of this thesis, aim of this thesis and used methods. The second chapter deals with basic terms of double taxation, general meaning of double taxation, tax legislation in Czech Republic and EU law concerning taxation. In following parts, it defines the term of double taxation, both intra national and international and its types. The third part describes the methods of elimination of double taxation, exemption and credit. The fourth part of describes limited and unlimited tax liability. The fifth part deals with tax residents and non-residents, the sixth part deals with transfer pricing. The seventh part discusses tax havens. The last, eight, part is concerned with transparent entities. The third chapter analyzes the international double taxation treaties, their history, importance and basic principles. In following parts, it describes types of these agreements, and in the last part, it describes the provisions of model...
|
|
|
International and national aspects of double taxation
Rogová, Tereza ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
This master's thesis aims to describe legislation of international and national double taxation. Furthermore, this paper deals with the term tax and puts down following questions: what does a tax represent; what is the subject of a tax; who is a resident and who is a non-resident. At the same time the master's thesis focuses on the history of international double taxation, consequences of double taxation and last but not least on the tax avoidance. The master's thesis is comprised of three chapters that are divided into more detailed subchapters. The first chapter deals with a tax as such in the Czech legal system and primarily deals with a tax as the most important source of financing of state budgets because the whole public sector is funded by taxes. Furthermore, it introduces to the issue of double taxation as a negative economic phenomenon for taxpayers and to the methods of the state intervention into a removal of double taxation whether national or international. In general the methods of prevention of double taxation are analyzed. The second chapter describes international treaties about prevention of double taxation. Nowadays taxpayers have a certainty due the international treaties about prevention of double taxation because they have a possibility to get to know the legal regime that will...
|
|
| |
|
|
Taxation of Rental Incomes in the Czech Republic
Kasalová, Kristýna ; Poláchová, Jana (referee) ; Brychta, Karel (advisor)
This bachelor thesis addresses the international taxation of a selected income category. Namely, it concentrates on the taxation of income of tax residents and non-residents of the Czech Republic arising from the rent of immovable property in the Czech Republic. In regard to the focus of the thesis, there are presented model situations that illustrate the method of taxation and the use of methods of avoiding double taxation.
|
|
|
Selected Specific Tax Resident in the Czech Republic
Kašparová, Hana ; Porubová, Pavla (referee) ; Svirák, Pavel (advisor)
The thesis is focused on individuals income taxes in Czech republic. It is mainly focused on certain individuals – residents and their duties to Czech republic. The thesis also shows the work of Czech law in certain, more complicated situations which can occur. In conclusion, the evaluation of whether the legislation for the avoidence of double taxations is sufficient or not.
|
|
| |
guest ::
