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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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International double taxation
Körbl, Hugo ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
práce v anglickém jazyce International double taxation International taxation is a very large topic. It is possible to write hundreds of pages about this subject but there will still be many problems which will be waiting for their solution. This theme is also very interesting and in this time very actual. I am sure that importance of international taxation will be highly raising in the future. This is caused by high intensity of the mobility of people and corporations, capital, services, and property but on on the other side it is caused also by still higher and higher number of tax evasions. The states are then forced to make a larger effort in cooperation between them and also to try to prevent the tax evasions. Double taxation agreements should be considered as a good solution for prevention of tax evasions and also mainly only these treaties can assure fair distribution of paid taxes between the states. It wasn't possible to make comprehensive analysis of this large subject in this relatively short thesis. So I decided to focus only on some issues of international double taxation. I was trying to choose issues which make often problems in application or issues which I am considering as very interesting. Sometimes the work on my thesis was not easy because of high number of different opinions....
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The tax system and agreements on the avoidance of double taxation
Pochmon, Zbyněk ; Bakeš, Milan (advisor) ; Kohajda, Michael (referee)
This diploma thesis entitled "The tax system and agreements on the avoidance of double taxation" analyses the Czech tax system and international double taxation, both generally and within individual contract models on the avoidance of double taxation. The diploma thesis is divided into three parts on this basis - the parts are dealing with tax system, international double taxation and agreements on the avoidance of double taxation. The beginning of the first part of this thesis is more theoretical. It contains a brief description of tax and tax system, analyses their basic elements (tax subject, tax object, tax base, tax rate and maturity of taxes) and divides taxes - the main partition is on direct and indirect taxes. This thesis, however, does not omit basic tax functions (fiscal function, allocation, redistribution, stimulation and stabilization) and the basic principles of taxes (legal perfection principle, the principle of tax fairness, tax efficiency principle, the principle of right effect on the behaviour of economic subjects and the principle of clarity of the tax system). The thesis also focuses on budgetary allocation of taxes. Subsequently, the thesis describes the Czech tax system. The description is based on individual taxes imposed in Czech Republic. These taxes are analysed on the...
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International double taxation
Odarčenko, Michal ; Vondráčková, Pavlína (advisor) ; Novotný, Petr (referee)
The topic of this thesis is the phenomenon of international double taxation. Collection of taxes is a manifestation of state sovereignty. Each state lays down its own rules determining which persons and economic facts will be subject to taxation. As a result a situation may occur that more states claim the right to impose a tax of comparable nature on the same fact and entity. Such situations ordinarily occur in connection with cross-border labour mobility, international investments, and in many other cases. Double taxation is a burden for taxpayers and represents a barrier to international movement of persons and capital. States may provide relief to taxpayers by unilateral measures. However, a more effective instrument for the avoidance of double taxation is international cooperation. The 20th century saw the development of international treaties on avoidance of double taxation, which have a privileged position in the tax law. These treaties not only serve as a relief to taxpayers, but are also the basis of comprehensive cooperation in tax collection. Therefore, this thesis focuses on double taxation treaties, which are currently the most effective tool for resolving a conflict of tax laws of different states. The thesis firstly deals with the treaties on avoidance of double taxation in general...
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Methods of double taxation avoidance and using thereof in the Czech tax law
Turek, Petr ; Kotáb, Petr (advisor) ; Kohajda, Michael (referee)
83 RESUMÉ Methods of double taxation avoidance and using thereof in the Czech tax law The Master Thesis deals with the methods of international double taxation avoidance as they are set out by the OECD (Organisation for Economic Co-operation and Development) and UN (United Nations) Model Conventions, as well as by the international bilateral treaties concluded by the Czech Republic based on these model conventions. The definition of the basic terms used by the Czech tax law is first set out by the Thesis. Then later the Thesis focuses on the two fundamental model conventions being the OECD model and the UN model, on the "model" treaty concluded by the United States of America, and on the double taxation avoidance international treaties in general - their role, reasons and possible use. The European law regarding the international double taxation shall also be mentioned, i.e. directives of the European Union, decisions of the Court of Justice of the European Union, or eventually the other initiatives brought up at the European Union bases. The fundamental part of the Thesis regards the methods of the double taxation avoidance: the exemption method and the credit method, including their types. Each of the mentioned methods (full exemption, exemption with progression, full credit and ordinary credit) is...
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The tax system and agreements on the avoidance of double taxation
Pochmon, Zbyněk ; Bakeš, Milan (advisor) ; Kohajda, Michael (referee)
This diploma thesis entitled "The tax system and agreements on the avoidance of double taxation" analyses the Czech tax system and international double taxation, both generally and within individual contract models on the avoidance of double taxation. The diploma thesis is divided into three parts on this basis - the parts are dealing with tax system, international double taxation and agreements on the avoidance of double taxation. The beginning of the first part of this thesis is more theoretical. It contains a brief description of tax and tax system, analyses their basic elements (tax subject, tax object, tax base, tax rate and maturity of taxes) and divides taxes - the main partition is on direct and indirect taxes. This thesis, however, does not omit basic tax functions (fiscal function, allocation, redistribution, stimulation and stabilization) and the basic principles of taxes (legal perfection principle, the principle of tax fairness, tax efficiency principle, the principle of right effect on the behaviour of economic subjects and the principle of clarity of the tax system). The thesis also focuses on budgetary allocation of taxes. Subsequently, the thesis describes the Czech tax system. The description is based on individual taxes imposed in Czech Republic. These taxes are analysed on the...
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International double taxation
Odarčenko, Michal ; Vondráčková, Pavlína (advisor) ; Novotný, Petr (referee)
The topic of this thesis is the phenomenon of international double taxation. Collection of taxes is a manifestation of state sovereignty. Each state lays down its own rules determining which persons and economic facts will be subject to taxation. As a result a situation may occur that more states claim the right to impose a tax of comparable nature on the same fact and entity. Such situations ordinarily occur in connection with cross-border labour mobility, international investments, and in many other cases. Double taxation is a burden for taxpayers and represents a barrier to international movement of persons and capital. States may provide relief to taxpayers by unilateral measures. However, a more effective instrument for the avoidance of double taxation is international cooperation. The 20th century saw the development of international treaties on avoidance of double taxation, which have a privileged position in the tax law. These treaties not only serve as a relief to taxpayers, but are also the basis of comprehensive cooperation in tax collection. Therefore, this thesis focuses on double taxation treaties, which are currently the most effective tool for resolving a conflict of tax laws of different states. The thesis firstly deals with the treaties on avoidance of double taxation in general...
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International and national aspects of double taxation
Levý, Michal ; Novotný, Petr (advisor) ; Kohajda, Michael (referee)
The main topic of this thesis is double taxation - the issue which gets more and more important, because national economies are going to be connected and international business develops, double taxation affects these activities strongly. Double taxation is considered to be negative phenomenon not only by private sector, but even states, so we can detect efforts for elimination or even reduction of this negative phenomenon. Because double taxation is very large topic it is not possible to cover it comprehensively, this diploma thesis is reduced only to some spheres and institutions of double taxation. The thesis is composed of three main parts. Theoretical introduction to the issue of double taxation mentiones the most important terms and principles of the double taxation and constitutes the basic for the following interpretation. Meaned are methodes and means used to eliminate double taxation with the practical example of their use and their comparison. The second chapter deals with internal aspects of double taxation and focuses on the Czech and EU legislation of double taxation. Attention is also paid to the Czech future double taxation elimination legislation of income from shares in profits and from similar profits and to its' consequences. The third chapter is concerned with international...
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International double taxation
Körbl, Hugo ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
práce v anglickém jazyce International double taxation International taxation is a very large topic. It is possible to write hundreds of pages about this subject but there will still be many problems which will be waiting for their solution. This theme is also very interesting and in this time very actual. I am sure that importance of international taxation will be highly raising in the future. This is caused by high intensity of the mobility of people and corporations, capital, services, and property but on on the other side it is caused also by still higher and higher number of tax evasions. The states are then forced to make a larger effort in cooperation between them and also to try to prevent the tax evasions. Double taxation agreements should be considered as a good solution for prevention of tax evasions and also mainly only these treaties can assure fair distribution of paid taxes between the states. It wasn't possible to make comprehensive analysis of this large subject in this relatively short thesis. So I decided to focus only on some issues of international double taxation. I was trying to choose issues which make often problems in application or issues which I am considering as very interesting. Sometimes the work on my thesis was not easy because of high number of different opinions....
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