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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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International Tax Optimization
Pavliska, Petr ; Havířová, Barbora (referee) ; Brychta, Karel (advisor)
This thesis deals with ICE - industrial services as The company must pay a withholding tax on their invoices received. Economic activity is undertaken in Germany. Company income from the supply of goods and services. Selected issue will be resolved by the formation of a permanent establishment or establishing a subsidiary in Germany. Developed solution provides the possibility of effective expansion into foreign markets. Results of the work allows the company to decide which option is best for her.
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Permanent Establishment in the Czech Republic and its Taxation
Balabán, Jaroslav ; Irein, Vítězslav (referee) ; Brychta, Karel (advisor)
The Diploma Thesis „Permanent Establishment in the Czech Republic and its Taxation“ deals with the issue of double taxation focusing on the income of the permanent establishment. The first part of the thesis is focused on theoretical knowledge of an international double taxation, concept of agreements for the avoidance of double taxation, definition of the term „Permanent establishment“ and the taxation of permanent establishment. The second part is aimed at analysis Article 5 of Agreements for the avoidance of double taxation. The third part comprehends a model examples of the resident of Slovakia.
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Comparison of Selected Forms of Doing Business by Foreign Legal Entities in the Czech Republic
Přechová, Renáta ; Šnajdrová, Jana (referee) ; Brychta, Karel (advisor)
The present diploma thesis is focused on the definition of differences resulting from the comparison of two chosen forms of doing business of a foreign person in the Czech Republic. It specifies differences from the viewpoint of the commercial law and the obligations as an accounting unit. Foremost, the thesis includes a detailed analysis from a tax point of view. The thesis involves a model example to define the precise amount of tax obligation incumbent on the both forms of business of a foreign person in the Czech Republic. This model example constitutes a basis for the final evaluation and to draw relevant conclusions. Suggestions and recommendations mentioned in this work can serve as an overview of the approach to the taxation of cross-border income and at the same time as a tool for the elimination of errors and discrepancies in connection with the chosen form of business of a foreign person in the Czech Republic.
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Interaction between double tax treaties and domestic law
Nešleha, Matěj ; Tepperová, Jana (advisor) ; Vančurová, Alena (referee)
The main aim of the diploma thesis is to identify situations of mutual interaction between double tax treaties and domestic law of income tax, in these situations there is not only one interpretation. This interaction is described by many actual discussed issues, which exists on the field of the income tax. Theese discussed issues are primarily about permanent establishment, first issue is about permanent establishment according to the double tax treaty between the Czech republic and Germany, second issue is about permanent establishment according to the double tax treaty between the Czech republic and Ukraine, last discussed issue is about information obligation of permanent establishment according to the czech income tax act. The sources of theese problem are judgements, professional literature and professional discussion (KOOV).
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Concept of International Taxation of Permanent Establishments
Sladkovský, Otakar ; Tepperová, Jana (advisor) ; Tecl, Jan (referee)
The diploma thesis deals with the concept of International Taxation of Permanent Establishments. The treatment of permanent establishment is defined and compared from both czech and international perspective. Furthermore, there are identified issues that individual countries and the international organization OECD have to deal with under the Action Plan BEPS. Moreover, at the end of the thesis frequency of permanent establishments in the Czech Republic is displayed according to the residence of taxpayers.
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Taxation of the Dependent Agent´s Revenues
Brožová, Kristýna ; Marková, Hana (advisor) ; Vybíral, Roman (referee)
The thesis deals with finding definition characters of agents as permanent establishments (dependent agents) available from publicly accessible sources, including its negative definition in comparison with the concept of an independent agent. The second part of the thesis analyses all possible and suggested ways of tax base creation, i.e. application of substitute methods of profit assessment and tax base enumeration from accounting profit or difference between revenues and expenses. Further this part of the thesis focuses on the issue of appropriateness of the Proposal for a Council Directive COM(2011) 0121 of 16 March 2011 on a Common Consolidated Corporate Tax Base (CCCTB) for dependent agent's purpose. Used methods include analogy, analysis, synthesis, deduction and comparison.
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Analysis of applicability and transferability of the corporation tax losses within the EU
Fuksová, Barbara ; Říhová, Lucie (advisor) ; Vančurová, Alena (referee)
This thesis analyses the treatment of tax losses in the Czech Republic in national and cross-border situations in the context of the recommendations of the European Commission and trends in treatment of losses, based on the cases of the European Court of Justice. Lack of immediate relief for losses leads to asymmetry of taxation, which is one of the causes of limitation functioning of the EU internal market. The comparison with other EU Member States based Czech Republic as a country with below-average possibilities of obtaining relief for losses. These include the 8 Member States have not yet adopted any national system of group taxation. Ways to get immediate relief for losses in domestic situations, including remains fiscally transparent entities in the group structure. Cross-border loss relief is available only if doing business in certain countries either by means of transparent entities or permanent establishments. This method of obtaining relief for losses is contrary to the interpretation of freedom of establishment, according to which there should be no discrimination on the basis of the legal form of business.
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