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Hybrid Mismatches After the ATADTheoretical Aspects of International Cooperation in Tax Matters
Hrdlička, Lukáš ; Boháč, Radim (advisor) ; Kohajda, Michael (referee) ; Matejová, Martina (referee)
Hybrid Mismatches After the ATAD Theoretical Aspects of International Cooperation in Tax Matters Abstract This dissertation argues that the current approach toward hybrid mismatches, i.e. linking rules, is ineffective and that EU Member States should consider and adopt other solutions to hybrid mismatches, in particular coordination rules, to achieve single taxation of cross-border income if it is their tax policy goal. I make this argument to help tax policymakers deal properly with hybrid mismatches while also achieving greater legal certainty for taxpayers and tax administrators. While pursuing my claim, I touch on the essential elements of current international taxation, describe certain sets of hybrid mismatches, discuss policy implications of hybrid mismatches' outcomes, and show what linking rules are and that they have many shortcomings. Consequently, I discuss various alternative solutions to hybrid mismatches and point out that coordination rules can be a better method to pursue. Using the preparatory discussion, I examine the Czech anti-hybrid mismatches rules and argue that EU Member States can, to some extent, still use coordination rules as a solution to hybrid mismatches under the ATAD. My analysis leads to practical and theoretical conclusions. I show that the academic literature does not...
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Hybrid Mismatches After the ATAD Theoretical Aspects of International Cooperation in Tax Matters
Hrdlička, Lukáš ; Boháč, Radim (advisor) ; Kohajda, Michael (referee) ; Matejová, Martina (referee)
Hybrid Mismatches After the ATAD Theoretical Aspects of International Cooperation in Tax Matters Abstract This dissertation argues that the current approach toward hybrid mismatches, i.e. linking rules, is ineffective and that EU Member States should consider and adopt other solutions to hybrid mismatches, in particular coordination rules, to achieve single taxation of cross-border income if it is their tax policy goal. I make this argument to help tax policymakers deal properly with hybrid mismatches while also achieving greater legal certainty for taxpayers and tax administrators. While pursuing my claim, I touch on the essential elements of current international taxation, describe certain sets of hybrid mismatches, discuss policy implications of hybrid mismatches' outcomes, and show what linking rules are and that they have many shortcomings. Consequently, I discuss various alternative solutions to hybrid mismatches and point out that coordination rules can be a better method to pursue. Using the preparatory discussion, I examine the Czech anti-hybrid mismatches rules and argue that EU Member States can, to some extent, still use coordination rules as a solution to hybrid mismatches under the ATAD. My analysis leads to practical and theoretical conclusions. I show that the academic literature does not...
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The rights and duties of self-employed persons working in the European Union with regarding to social securement.
TOMANOVÁ, Leona
The Bachelor thesis deals with the rights and obligations of self-employed persons working within the European Union with a focus on social security. The thesis is divided into two parts. The first part is theoretical and the second one is empirical. In the theoretical part, the basic facts about the rights and duties of self-employed migrants in social security are presented, that are summarized using available literature and current legislation. These systems are constantly changing and therefore the information only relates to the current state. In the empirical part, the goal was to find information about self-employed persons about their duties and rights when moving within the European Union with a focus on social security. The research part was performed by a qualitative research strategy and through a semi-structured interview. The results are processed by groups and they are graphically displayed using tables. The communication partners were chosen by the method of effective selection. Ten migrant self-employed person were chosen. The research has highlighted the importance of self-employed persons being introduced to their social security rights and obligations in the European Union, not only because of their better information, but also because the number of self-employed persons in more states of the European Union is steadily rising. In mapping the legal awareness of the self-employed, it turned out that only half of the respondents were able to refer to most of the questions asked. The results of the work could be beneficial for students in social sciences and for working persons who come into contact with this issue.
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