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Tax Havens and Their Use
Komárková, Renata ; Filipová, Vladimíra (referee) ; Kopřiva, Jan (advisor)
This master thesis deals with the characteristics of tax havens, approach beneficiary companies and way of their use and potential abuse. The first part defines basic terms, which are tax havens are closely linked. The second part is devoted to the characterization chosen tax havens in different areas of model-based taxation example of two types of companies. The third part contains the suggestions and recommendations for setting up a company in a tax haven.
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International Tax Planning and its Impact on Company's Economy
Vlk, Tomáš ; Koutný, Jiří (referee) ; Kopřiva, Jan (advisor)
Aim of my master’s thesis on the topic „International Tax Planning and its Impact on Company's Economy“ is to evaluate current business model of the firm Jelko which is using it for products selling to the Slovakia. Based on the currect model analysis I will introduce other models, which could cause higher efficiency of advantageousness. I will analyse advantages and disadvantages of each model and following this analysis I will choose the best model which I will recommend to the firm in order to consider it and eventually to implement it.
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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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Optimization of firm´s tax liability
Horák, Jan ; Kislingerová, Eva (advisor) ; Synek, Miloslav (referee)
The main objective of this Master's thesis is to analyze the regulation of tax liability of legal person and on the basis of the analysis to reveal opportunities for optimization of the tax liability by means of practical examples of the application of tax optimization. To achieve this objective, the work is divided into five main chapters. The purpose of the first four chapters is to provide a sufficient theoretical base connected with tax optimization. This section begins with the interpretation of general problems of the theory of corporate taxes, which gradually passes into the interpretation of more specific areas. In the following part of the work the selected methods of tax optimization are used on illustrative numerical examples, the conditions for the application of optimization methods are determined and the situation before using the optimization and after the use is compared. The conclusion summarizes the possible ways of reducing the tax burden of the firm and the possibility of their practical use.
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The impact of the tax havens on the public finance of Slovakia
Pištejová, Jana ; Janíčko, Martin (advisor) ; Mičúch, Marek (referee)
International tax planning deals with the tax benefits, their seeking and using by the tax entities and corporations. Even if the tax havens are generally considered as small islands, the different types of tax advantages are offered by the developed countries of the North America or Europe. This paper focuses on the analysis of the inward of foreign direct investments into the European countries with the preferential tax regimes. It explains the relationship between the inward of the investments and the factors which affect them. The inward of the foreign direct investments is the dependent variable, the independent variables are tax rates on corporate income, unemployment, as well as political stability. Although results of econometric analysis did not confirm our initial hypothesis that the lower tax burden will increase the inward of the investments to the country, this increase can be caused under the other circumstances, such as secrecy, property protection, stable political situation or simplicity and utility of the financial markets.
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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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Tax planning in corporation
Nevodnicheva, Yulia ; Kislingerová, Eva (advisor) ; Dvořáček, Jiří (referee)
This thesis "Tax planning in corporation" puts brain to legal entity income tax and it is looking for possible solutions in tax planning in corporation. The first part deals with the tax theory, the other part is the theory of tax planning, comparison of tax regimes and tax policy and tax revenue by optimizing both internationally and in the local aspect. The last part discusses options for optimizing tax
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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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Transfer-pricing-based tax planning
Lhotský, Vladimír ; Buus, Tomáš (advisor) ; Kuncl, Karel (referee)
This work brings a systematic approach to the design of a transaction-based transfer-pricing policy of a multinational group and related tax optimization. The foundation of the work is a description and analysis of all aspect of the transfer-pricing regulation including a detailed classification of particular business risks. Using a certain simplification of the complicated relations in multinational groups, a system compliant with transfer-pricing rules is designed, hence minimizing the tax risk. Further, I devote my attention to rather complicated areas of transfer-pricing like pricing of payments for intangible property, pricing in non-standard structures and allocation of exchange rate risk. After the build-up of the architecture of the transfer-pricing system, analysis of the tax optimization possibilities adhering to all regulatory requirements is carried out. The detailed description of the tax effective supply chain management planning concept and other planning instruments is presented. The final part is devoted to the negative tax implications of business restructuring steps analyzed on the examples of particular structures.
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Analysis of case law from the perspective of abuse or circumvention of the tax law
Růžičková, Tereza ; Kubátová, Květa (advisor) ; Schvábová, Andrea (referee)
Everyone seeks to minimize his tax liability. Generally, we can say that reducing the tax burden takes several forms. In this diploma thesis I deal with specific area - "tax avoidance", which is properly defined in the first chapter. Analysis and subsequent synthesis of the jurisprudence of the Supreme Administrative Court evaluates the current state of interpretation and usefulness of individual instruments by the tax authorities "correct" avoidant behavior of taxpayers. Interpretation of Czech courts is supplemented by a specific key court decisions of the European Court of Justice, defining the rules of one particular instrument. Finally, a Czech tax policy recommendation on the need for adaptation and mainly the general principle against tax avoidance in the Czech tax law could be found at the end of this thesis.
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