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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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Legal regulation of taxation of sportsmen
Navracký, Zdeněk ; Marková, Hana (advisor) ; Kohajda, Michael (referee)
Legal Regulation of Taxation of Sportsmen Abstract / Summary: This thesis deals with sportsmen taxation in the Czech Republic and in foreign countries, especially in Germany. The first chapter, following the introduction, is made of fundamental concepts related to this topic (tax, charge, subject to taxation, income-tax, value-added tax, gift tax). Chapter Two of this paper discusses the status of sportsmen in the Czech Legal system and determination is made in terms of professional sportsmen, semiprofessional, amateurs and and in terms of the way powering the sport, either personally or collectively. The third chapter deals with the legal status of professional sportsmen and their classification of particular taxes, emphasis is placed on tax on personal income. However, a brief excursion is made into value-added tax also. Chapter Four is dedicated to the issues of international taxation on sportsmen, because it's apparent the sport is overall activity which cannot be limited by boundaries. Chapter Five coming before the Conclusions is discussing briefly the German legislation in force influencing the taxation of sportsmen issues. Key Words: Sport, sportsman, income tax, value-added tax, gift tax, international taxation, the Czech Republic, Germany.
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Model agreements on double taxation avoidance in the practice of the Czech Republic
Taschner, Lukáš ; Kotáb, Petr (advisor) ; Novotný, Petr (referee)
This thesis deals with international taxation, which is becoming an increasingly important issue due to the globalization of world economy in recent decades. International taxation is a broad topic including a variety of problems concerning it. Among the most important recognized phenomena are International double taxation and tax evasion. The conclusion of bilateral tax treaties seems to be the most efficient instrument for their solutions so far. Model Tax Conventions have been prepared by international organizations for the purposes of coordination of structure, wording and interpretation of numerous bilateral agreements. The OECD Model Treaty and the UN Model Treaty are widespread worldwide, being legally non- binding models for negotiations of bilateral agreements. In addition to those, the proposal of a new multilateral European Union Treaty has appeared. It should be signed by all members of the European Union, and it would replace all bilateral agreements concluded between the EU member states. Within the global community of other states and nations, the Czech Republic has an open and liberal economy. Therefore, it is necessary for the Czech Republic to have all international tax issues ensured with each economic partner. Over the past twenty years, the Czech Republic has concluded 67 out...
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Taxation of income of business companies and their members (comparison of legal regulation in the Czech Republic and Slovakia)
Důjková, Zuzana ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
75 Resumé v anglickém jazyce a klíčová slova Taxation of income of business companies and their members (comparison of legal regulation in the Czech Republic and the Slovak Republic) My diploma thesis called "Taxation of income of business companies and their members (comparison of legal regulation in the Czech Republic and the Slovak Republic)" focuses mainly on the differences between legal regulation of system of income taxation in the Czech and Slovak Republic. Whereas a business company could be considered solely a legal entity, a member of a business company could be an individual as well. Therefore both areas of income taxation - personal and corporate income tax - are included into the comparison in this diploma thesis. After the introduction the thesis is divided into seven chapters. The first one describes the most important characteristics of particular business companies as they are stipulated in Act No. 513/1991 Coll., Commercial Code, as amended. I have introduced the key features of the most known legal forms of business companies - general partnership, limited partnership, limited liability company and joint stock company. The legal regulation of these types of business companies is similar in the Czech and Slovak Republic. The second chapter deals with legal regulation of both personal and...
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International taxation of employees
Koblasová, Zuzana ; Rytířová, Lucie (advisor) ; Tepperová, Jana (referee)
The diploma thesis is focused on the international taxation and local taxation of employee in the Czech Republic and Germany. It includes the both, theoretical and practical interpretation, which is shown by using the model example. In this example is calculated tax for resident in both countries, and the related social security. Using the example verifies the hypothesis which says that the tax wedge for the taxation of married couples with two children is less than the tax wedge on individuals without children. Another goal is to show the differences in the calculation of tax and related deductions from the tax base, tax rate and tax credits. There are shown the differences in the calculation of tax and duties arising for employees in the case of resident and non-resident in both countries and also tax wedge on wage.
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Personal Income Taxation in the Czech Republic and the United States of America
Doubravová, Lucie ; Rytířová, Lucie (advisor) ; Tepperová, Jana (referee)
This diploma thesis describes the topic of personal income taxation in the Czech Republic compared to the United States of America and on the case studies it compares the tax burden of the family with two children earning average income from employment in the Czech Republic and in the United States of America. The aim is to prove that the results comply with the OECD statistics saying that the tax burden difference between those two states is approximately the same. The fractional aim is to examine if the tax burden for the same family with the above-average employment income in the United States is much higher that it can be one of the motives why people enter or leave different labour markets. The second case study focuses on the differences in the taxation of the different tax return categories of the taxpayers and confirms the theory that the average benefit of 450 USD per year appears with taxpayers filing the married filing jointly tax return. The thesis also describes the international taxation basics with the Double tax treaty and the concepts of tax residence and taxation principles such as tax equity and efficiency.
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Tax and social security systems in selected EU countries
Vágnerová, Pavlína ; Tepperová, Jana (advisor) ; Čejková, Eliška (referee)
The aim of this master thesis is the comparison of selected elements of the tax and social security systems in the Czech Republic, Slovakia, Austria and Germany, which are related to employees and employers and it is counted with them in model examples, then evaluation of advantages and disadvantages of employees´ migration under the structure of posting between the Czech Republic and other countries and finally the comparison of employees´ incomes after receiving benefits from social security system of each country (especially old age pension and parental allowance). In the first part of the thesis there is explained problematics of double tax treaties and EU coordination of social security. Then there is the comparison of above mentioned elements of the tax and social security systems in each country. In the last part I apply findings on model employees and I make a conclusion from amount of their net incomes. Migration to another EU member country is the most profitable for employee who is subjected to taxation in other EU countries but he remains under the Czech social security system. In terms of social benefits, retired people are supported the most in Austria and families with children in Germany.
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Tax Havens
Šoltés, Lukáš ; Polanský, Tomáš (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis deals with the tax haeven and the tax optimization. In the teoretic part are the teoretic starting-points for this theme and in the analytic part is selected one tax haeven for the company, in wisch is calculated how much to save in the tax haven.
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International Tax Optimization using Offshore and Onshore Jurisdictions in the European Union
Skalická, Magdaléna ; Křivohlávková, Jitka (referee) ; Brychta, Karel (advisor)
This thesis is focused on corporate structure designs with the use of offshore and onshore centers in the European Union for the optimization of tax on corporate income . The work is divided into theoretical and analytical sections as well as a section with proposals. The theoretical section describes the problems of international tax planning and international taxation, focusing on offshore and onshore financial centers. In the analytical section there are various offshore and onshore financial centers in the European Union identified and outlined with selected analyses in more detail, especially of the corporate taxation. The practical part describes a model of the corporate structure with the use of selected offshore and onshore centers in the European Union and the various options for resolving tax optimization.
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International Taxation of Dividends
Jurčáková, Renata ; Vašíčková, Vladislava (referee) ; Brychta, Karel (advisor)
The Master’s thesis is focused on international taxation of dividends from the perspective of legal entities. With regard to the scope of the topic deals with, the thesis focuses only on taxation of dividends issued by holding companies. The Master’s thesis deals with description and analysis of the relevant legislation, that is international, union and domestic legislation. The knowledge of the analysis is applied in recommendations for holding companies.
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