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European Tax Havens - Case Study
Dendisová, Zuzana ; Hraba, Zdeněk (advisor) ; Dupáková, Lenka (referee)
Diploma thesis "Tax Havens in Europe- Case Study" analyses offshore business in Europe at the turn of years 2017 and 2018 from legal and economic perspective. The first chapter is an introduction to tax havens. The second chapter clarifies legal regulations of offshore business in Europe. The third chapter applies theoretical knowledge from previous chapters in a case study.
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Legal aspects of tax planning in the direct tax area
Kamínková, Petra ; Karfíková, Marie (advisor) ; Boháč, Radim (referee) ; Papoušková, Zdenka (referee)
Title in English: Legal aspects of tax planning in the direct tax area Abstract: In 2012, the European Commission published its Recommendation on aggressive tax planning (2012/772/EU). To counteract aggressive tax planning, Member States should adopt a general anti-abuse rule (GAAR), which is drafted in the Recommendation. At that time, no one knew that GAARs would become obligatory for member states from 2019. In 2013, Organization for Economic Co-operation and Development (OECD) started the BEPS Project, which is considered the biggest revolution in the international tax law system since its creation in the 1950s. I introduce these initiatives and the legal instruments they bring. I focus on GAARs, which I consider to be the most important instruments. Their vagueness allows them to tackle any tax planning scheme. Their importance in the direct tax area grows as they become part of tax treaties based on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed on 7 July 2017 and part of the national legal systems of the EU member states based on the Council Directive (EU) 2016/1164 of 12 July 2016, laying down rules against tax avoidance practices that directly affect the functioning of the internal market. First part of this thesis focuses on...
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Comparison of the corporation tax base in selected OECD countries
Dzhalavyan, Arutyun ; Láchová, Lenka (advisor) ; Kouba, Tomáš (referee)
The main aim of my thesis is to compare the legislative regulation of corporate taxation in selected OECD member states with a focus on the tax base. The partial aim of my work is to determine the impact of BEPS actions on corporate taxation not only as a whole, but also within selected countries. This thesis is focused on Great Britain, Belgium and Spain. The first part of this thesis introduces us the relevant concepts, the subsequent chapter focuses on the BEPS initiative and in the last part of the thesis deals with the legislative regulation of the corporate taxation in the selected countries and their comparison.
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Analysis of Aggressive Tax Planning Related to Mergers of Companies And Cooperatives
Foltysová, Nikol ; Finardi, Savina (advisor) ; Tecl, Jan (referee)
The diploma thesis deals mainly with aggressive tax planning of multinational companies but also mentions the practices of domestic enterprises, which lead up to the reduction of the tax liability of the entity. The main idea of the thesis is a description of indicators and the analysis of structures of companies performing aggressive tax planning. The practical part of this thesis contains model examples, which can be realized and against which it is necessary to intervene. The last chapter describes measures by which the OECD and the European Union institutions are trying to eliminate the abuse of tax laws and bilateral treaties by multinational corporations. The Czech Republic has already implemented a number of measures against aggressive tax planning, which success in this diploma thesis is tested by comparing year-by-year revenues changes from corporate income tax.
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Limits to Global Tax Cooperation: Unsuccessful Negotiations in the United Nations
Březovská, Romana ; Parízek, Michal (advisor) ; Karlas, Jan (referee)
In view of the adopted SDGs in 2015 and their focus on domestic resource mobilisation, this diploma thesis attempts to fulfil two main objectives. First, it aims to describe and analyse the current tax system often labelled not only by developing states as unfit for the 21st century's globalized economy. Second, it tries to provide deeper understanding of reasons that lead certain countries not to support the creation of a UN Tax Body, the only platform where all countries could participate in the negotiating of tax harmonization on an equal footing. Three hypotheses based on a neorealist, liberal and functional regime theory are put forward. Using data obtained from interviews conducted with delegates at the UN, it can be concluded that the organisational infrastructure is the power reflection. While the OECD BEPS mechanism is recognised by many as efficient and sufficient, this is possible due to the enabling power relations that exclude more than hundred developing countries from the negotiation of international tax rules. It can thus be concluded that the current OECD mechanism does not address existing policy loopholes that cause losses to developing countries. To match the SDGs' rhetoric with reality, policy-makers should create a more inclusive and universally agreed on standard-setting...
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EU's Measures Against Income Tax Optimalisation
Hortíková, Kateřina ; Tepperová, Jana (advisor) ; Tecl, Jan (referee)
This diploma thesis provides an analysis of the Anti-Tax Avoidance Package (ATAP) proposed by European Union. This package was adopted in relation to OECD's Base Erosion and Profit Shifting (BEPS) project. It consists of measures that aim to reduce the level of tax avoidance caused mainly by base erosion and profit shifting within multinational corporations. The theoretical part of the thesis consists of brief introduction of the BEPS project, followed by detailed analysis of the EU package. The practical part tends to analyse the possible impact of the package implementation in Czech Republic on selected measure, tax limitation of paid interests deductibility. Real data of three Czech companies were used for the analysis. The author used the method of a case study to compare tax impacts of current thin capitalisation rule application against the proposed rule limiting the interest deductibility up to 30 % of EBITDA.
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Methodology for determining transfer prices in the Czech Republic and the the United States
Horák, Štěpán ; Tepperová, Jana (advisor) ; Kostohryz, Jiří (referee)
The aim of this study is to compare the methodology for determining transfer prices in the Czech Republic and the United States. The reason for choosing these countries are different models, which are governed by states. Czech Republic sets transfer prices according to the OECD model. United States of America set transfer prices according to own regulations. The theoretical part is focused on comparing models and approaches to pricing methodologies. The practical part compares the creatin of a Benchmarking study in these two models.
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The world of Post BEPS transfer pricing
Sadilová, Michaela ; Frýzek, Libor (advisor) ; Zídková, Hana (referee)
The aim of this diploma thesis is to analyze impacts of BEPS including Country-by-Country reporting on the business field and on the tax administration. The theoretical part describes the importance of the initiative of BEPS transfer pricing including its the updated package, Action 8-10. Next part describes and compares the actual transfer pricing regulations in the countries of Visegrad 4 and in Germany. The last part of the diploma thesis analyzes the current transfer pricing situations and the cases of multinational corporation such as Google and Starbucks and it is followed by chaptures analyzing possible advantages and disadvantages that will arise from the new statement of CBCR.
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International cooperation in the fight against tax evasion in the field of direct taxation at the level of OECD and EU
Burešová, Lucie ; Finardi, Savina (advisor) ; Tecl, Jan (referee)
The thesis deals with international cooperation in the fight against tax evasion in the field of direct taxation at the level of OECD and EU. First, the thesis explains why international tax evasion occurs, what the most common forms of tax evasion are and also how multinational companies use international, sometimes even aggressive, tax planning to reduce the tax burden. The next section specifies diverse measures already adopted within the OECD and the EU and also those that are still in preparation. Any action taken at the international level is put into context with what the Czech Republic has already introduced. Mutual exchange of information between countries is one of the most important tools in the fight against tax evasion. That is why an analysis of spontaneous exchange of information and on request between CZ and other cooperating countries was carried out in the last part of the thesis. The analysis was carried out on the basis of publicly available data from Annual Reports of Financial Administration of the Czech Republic and also on the basis of data which were received from the Department of international tax cooperation - direct taxes of General Financial Directorate.
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Tackling Tax Evasion: Overview of Transactions with Related Parties
Hospodka, Jan ; Francírek, František (advisor) ; Finardi, Savina (referee)
The topic of this thesis is transfer pricing, its significance in international trade and the on-going effort to create appropriate tax rules by both international organisations and the Financial Administration of the Czech Republic. My thesis has a particular focus on a new disclosure to a company's income tax return, that is, the Overview of Transactions with Related Parties. The theoretical part of this thesis addresses the function and significance of transfer pricing in international trade as well as the current development in international and domestic transfer pricing rules. The practical part focuses on an analysis of how the connections between the Overview of Transactions with Related Parties and the financial statements of entities help the Financial Administration to derive significant ratios and conduct systematic data collection to analyse transactions with related parties and detect which entities to audit.
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