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BEPS and its impact on the tax system of the Czech Republic
Chrien, Kristián ; Láchová, Lenka (advisor) ; Kouba, Tomáš (referee)
The aim of this diploma thesis is to analyze the BEPS measures for the digital economy in connection with the relevant measures related to this sector of the economy. The first part of the thesis characterizes the digital sector and its key business models. The main risks in the field of direct and indirect taxation are described below. The second part of the thesis analyzes the BEPS special measures related to the digital economy sector as well as other measures related to the digital economy. The third part of the thesis describes measures for the digital sector within the framework of the Anti-BEPS initiative, which took place in the European Union. Describes measures under the ATAD Anti-Tax Avoidance Directive in three new areas not addressed by the BEPS project. This section also addresses the measures contained in the DAC Administrative Cooperation Directive and the EU Action Plan for Fair and Efficient Taxation of Corporate Income. The last chapter deals with the analysis of proposed solutions from the point of view of the Czech Republic. It models specific measures within a permanent establishment and withholding tax on the digital economy sector in the Czech Republic, specifically on the field of web hosting. The goal is to quantify the possible impact on tax collection from transactions falling within the web hosting business model.
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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...
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The institution of a permanent establishment in tax law
Vaněk, Marek ; Kotáb, Petr (advisor) ; Vybíral, Roman (referee)
1 Abstract Title: The concept of the permanent establishment in the tax law Author: Marek Vaněk Supervisor: JUDr. Petr Kotáb, Ph.D. This thesis analyses the law concept of the permanent establishment, mainly the legislation contained in the OECD Model Tax Convention and in the Income Tax Act. The first part of the thesis analyses the types of permanent establishment (fixed, building and construction sites, service-based, agent-based and permanent establishment of the shareholders of partnerships and limited partnerships), separately according the OECD Model Tax Convention and according to the Income Tax Act. The thesis also analyses subsequent sources of law. The thesis includes a detailed analysis of conditions which are necessary for the existence of the permanent establishment, inclusive examples, including information of the Ministry of finance and the General Financial Directorate that have impact on the permanent establishment treatment. Furthermore, the thesis deals with the determination of the tax residency of persons and legal bodies which is a significant factor for the application of bilateral double taxation treaties (mainly with the circumstances of the existence of the permanent establishment), including the issues connected with proving of the tax residency of the tax transparent entities....
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Expatriate Taxation
Britz, Thomas ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
RESUMÉ IN ENGLISH Thomas Britz Expatriate Taxation With globalisation increasing, the tax aspects connected to the free movement of employees around the world are of particular importance to companies with subsidiaries around the globe. The goal of my thesis is to explore the risks involved in expatriate taxation. The first chapter is dedicated to the definition of the terms employment and secondment from the point of labour law, European social security coordination law and tax treaties. I think that the main characteristic of employment consists in the fact that it is the opposite of entrepreneurialism. The second chapter explores the general function of taxation, double taxation and its avoidance by bilateral tax treaties. Chapter three introduces the reader to discrimination in trans-border income tax cases and analyses the Schumacker ruling of the European Court of Justice, as a result of which tax reliefs can now be claimed in the European Union by non- residents, provided that 90% of their income originates from employment in the country that provides for such tax reliefs to its own residents. Chapter four discusses the definition of tax residence, the determination of residence under the Czech Income Tax Act and establishes when individuals are considered tax residents due to, inter alia, domicile...
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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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Application of the Convention for Avoidance of Double Taxation between the Czech Republic and Cypriot Republic
Pěta, Jan ; Fojtů, Dagmar (referee) ; Brychta, Karel (advisor)
This bachelor´s thesis convention for avoidance of double taxation between the Czech Republic and the Cypriot Republic and focuses on the taxation of natural persons incomes. It covers the double taxation history and the basic concepts used in the international taxation sphere. Also, methods of tax collection from persons who are not residents of the Czech Republic are clarified. The end of the theoretical part of the thesis explains methods of double taxation prevention. The practical part introduces the case of the resident of Czech Republic who has income both in the Czech Republic and in the Cypriot Republic.
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Application of the Convention between the Czech Republic and the Republic of Austria for Avoidance of Double Taxation
Přechová, Renáta ; Šnajdrová, Jana (referee) ; Brychta, Karel (advisor)
The present thesis deals with the articles of the double taxation agreement concluded between the Czech Republic and the Republic of Austria. Its aim is to highlight the solution of problems concerning the jurisdiction in the state of source and the jurisdiction in the state of residence. It shows how the methods to prevent double taxation are to be applied. It compares the differences in tax obligation of a resident of a country with which the Czech Republic has not concluded an agreement on precluding double taxation with the obligation of a resident of the Republic of Austria, which is a contracting country. It proves the justification of the existence of agreements on precluding double taxation by means of concrete examples and points out the necessity of their continual updating.
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