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APLICATION OF CONVENCION BETWEEN THE CZECH REPUBLIC AND THE REPUBLIC OF AUSTRIA FOR THE AVOIDANCE OF DOUBLE TAXATION
 KREMEROVÁ, Eva
The aim of diploma thesis is to analyze realization of a Convention for the avoidance of double taxation between the Czech Republic and the Republic of Austria. The paper explains what the international double taxation is and describes the types and methods of its prevention. It describes difference between tax residents and tax nonresidents. Further it describes development of Conventions for the avoidance of double taxation between the Czech Republic and the Republic of Austria and compares the Convention No. 48/1979 and No. 31/2007 which were applied in mutual tax relations between both countries. The paper is mainly focused on the situation of Czech tax residents who receive incomes from employment in Austria and shows on practical examples how the situation developed from 2007 to present. It describes the complicated situation of taxpayers in 2008, when they first proceed according to a new Convention between both countries and explains the calculation of the "super-gross wage" when incomes are from employment abroad. The paper also describes the approach to Austrian taxation of interest payments and resolve procedure Czech taxpayers in these cases. Finally, this paper examines the attitudes of both countries to adhere to Convention for the avoidance of double taxation and describes the difficult situation of Czech taxpayers with incomes from Austria.
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