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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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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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Tax havens and offshore companies
Taxová, Dominika ; Finardi, Savina (advisor) ; Vančurová, Alena (referee)
The aim of the bachelor thesis is comparison of the tax burden in selected offshore jurisdictions and in the Czech republic. In the first part are summarized the basic characteristics of offshore companies and destinations in which they are established. In the second part are explained principles of international taxation and the methods of use of offshore companies and their regulation. The third part of the work includes concrete examples that compare different tax burden.
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Taxation of income of professional athletes
Pacholík, Václav ; Slintáková, Barbora (advisor) ; Kozubíková, Pavlína (referee)
The main objective of the Thesis is to specify the crucial aspects of professional football players income taxation in the Czech Republic. These incomes are taxed according to the section 7 Income Tax Law. The Thesis is also aimed at taxation of non-resident football players. The international taxation is explained on the Model Tax Convention on Income and on Capital and on the Czech Income Tax Law. In the second part of this Thesis the fictious tax duty of selected football palyers is layed down. key words: professional football player, income tax, income tax
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Investment funds taxation
Karásková, Veronika ; Vančurová, Alena (advisor) ; Peroutka, Vojtěch (referee)
The aim of the diploma thesis is the analysis of investment funds taxation in the Czech Republic based on comparison with taxation of investment funds in Luxembourg, Germany and Ireland. The first part is focused on the analysis of legal but mostly tax arrangement of investment funds in the Czech Republic. The taxation is being analyzed on the level of invesment funds and also on the level of investors. The aim of the second part of the thesis is to analyze legal and tax arrangement of chosen EU states. The key issue is the comparison of tax arrangement of investment funds in Czech Republic with the tax arrangements of investment funds in chosen states which is also content of the third part. At the end of the last part the international taxation of investment funds and investors is mentioned as well as planned changes in investment funds taxation since 2015.
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Double Taxation Treaties and their Influence on Business Activity
Tuláčková, Anna ; Černohlávková, Eva (advisor) ; Smrčková, Michaela (referee)
The thesis is focused on international double taxation and its implications for international business activity. At first, it focuses on double taxation definition, the reasons of its occurrence and its impacts. The next part deals with bilateral double taxation treaties and their principles, including a comparison of Model conventions developed by the OECD and the UN. The last chapter focuses on the areas of transnational corporations activity that are most impacted by tax matters, such as the form of their presence in the foreign market, transfer pricing and international labour hire. The basic principles of international tax planning are explained as well.
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Possibilities of international tax planning for selected countries
Jauker, Michal ; Vítek, Leoš (advisor) ; Mareš, Milan (referee)
This thesis puts brain to possibilities offered to companies with domicile in the Czech Republic via international tax planning, lawful usage of these possibilities for tax liability optimization and increase of company profits. Major part of the thesis is dedicated to theoretical ways of international tax planning utilization for selected model. Cyprus, Ireland and Netherlands are included among main surveyed countries. There are described ways how can be reduced most effectively the tax liability of selected active and passive incomes.
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Taxation of permanent establishments
Stehno, Pavel ; Vančurová, Alena (advisor) ; Jelínek, Michal (referee)
Taxation of permanent establishments is one of the most complicated areas within international tax law. The system of permanent establishment is based not only on the national legislations of relevant states, but also (mainly) on the international double taxation treaties. This diploma thesis analyses those issues in the taxation of permanent establishments, which are the most up-to-date or can be considered as the key questions of the whole concept and therefore can be significant for the future development of the permanent establishments. However the technically perfect system of permanent establishments should come hand in hand with the practical feasibility and overall efficiency. This assumption is nowadays challenged by several trends like the growing popularity of offshore tax heavens or the development of information technologies, which complicate the determination of (fixed) place of business through which the business of an enterprise is wholy or partly carried on. The technical analyses in this thesis are, therefore, supplemented by the objective evaluations from the perspective of valid legislation, possible approaches of the tax authorities, as well as of the enterprise considerations and also the global international taxation picture. This involves also the aspects of tax policies at the level of sovereign states, especially the Czech Republic.
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