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International Double Taxation
Vašíčková, Pavlína ; Fajkusová, Ivona (referee) ; Brychta, Karel (advisor)
This bachelor’s thesis deals with issue of international tax relations. It is about the general background of this area, i.e. about intranational tax law in connection with conventions on avoidance of double taxation, cooperation of international tax administration, includes also analysis of nowadays situation and the practical outcome that deals with taxation process.
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Taxation of Dividends of Czech Republic Tax Non-residents
Krčmová, Michaela ; Svirák, Pavel (referee) ; Brychta, Karel (advisor)
This bachelor thesis is concerned about taxation of dividends which are payed out from Czech Republic sources to tax non-residents – natural persons. Describes, analyzes and systematized domestic legislation and international agreements related to the focus of thesis. In the practical section the methodical procedure for the payment of profit shares, or advances on them, and their taxation, is determined on model cases. Emphasis is placed on the definition of differences depending on the state in which the owner of the income is tax resident.
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International Tax Planning and Optimization
Kopecká, Jana ; MBA, Kateřina Franková, (referee) ; Brychta, Karel (advisor)
The diploma thesis focused on international tax planning and tax optimization. The diploma thesis specifies what is an international tax planning and underlines its importance in these days. On theoretical knowlege the diploma thesis summarizes key factors that should entrepreneurs in international tax planning and optimization to take into account. End of the thesis presents proposal the progress of the process of international tax planning and also on the particular case.
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Taxation of Rental Incomes in the Czech Republic
Kasalová, Kristýna ; Poláchová, Jana (referee) ; Brychta, Karel (advisor)
This bachelor thesis addresses the international taxation of a selected income category. Namely, it concentrates on the taxation of income of tax residents and non-residents of the Czech Republic arising from the rent of immovable property in the Czech Republic. In regard to the focus of the thesis, there are presented model situations that illustrate the method of taxation and the use of methods of avoiding double taxation.
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International double taxation
Řezníčková, Markéta ; Kotáb, Petr (advisor) ; Sejkora, Tomáš (referee)
This diploma thesis deals with some questions of the international double taxation, particularly with the basic terminology and principles of the international taxation, bilateral double taxation treaties and new tools of legal regulation of the international double taxation such as BEPS, MLI, a package of European directions called Anti-BEPS and its implementation into the Czech law. The aim of this thesis is to identify, describe and analyse sectional questions in respect to long-term and current evolution. In the introduction I briefly introduce the topic. Afterwards the thesis is divided into four chapters that are linked to each other. The first chapter presents to the reader basic terminology and explains basic principles of this field independently and in relation to current legal regulation. Further I describe the types of double taxation and other institutes related to the international double taxation such as international double non-taxation. The second chapter deals with means of elimination of the international double taxation. Two basic methods are described and some of them are represented by basic examples. There are also described means of elimination of the international double taxation that can only be used in tax treaties (not in the national law). The last subchapter describes...
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Double taxation treaties
Klener, Jan ; Vybíral, Roman (advisor) ; Kotáb, Petr (referee)
1 Abstract Double taxation treaties The diploma thesis focuses on the double taxation treaties with an objective to provide a qualitative evaluation of this legal institute, introduce positive and negative aspects of the institute. Subsequent purpose is to falsify the two hypotheses stated in the introduction. The first section discusses the history of taxation, the history of double taxation treaties and clarify the causations for their creation. Furthermore, the thesis presents individually relevant legal terms that are crucial for the comprehension and proper application of international double taxation treaties. Besides to legal terms, the thesis with doctrinal terms and economic terms in order to clarify the difference in the term of double taxation. The next section deals with the international double taxation treaties themselves, with their origin and the place in Czech legislation. Afterwards a description of the methods of avoiding double taxation is accomplish jointly with the comparison of the differences in the variant types and subtypes of methods. At the conclusion of section 4, application examples of individual methods of avoiding double taxation are analyzed. The final section of the thesis discusses present issues related to double taxation treaties. Description process of present legal...
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Double taxation avoidance treaties
Dík, Lukáš ; Karfíková, Marie (advisor) ; Vybíral, Roman (referee)
Treaties for the avoidance of double taxation This thesis deals with treaties for the avoidance of double taxation, which initially gives a general definition of taxation, then the essential elements of treaties for the avoidance of double taxation and based on the analysis and comparison draws conclusions. The thesis aims to give a comprehensive overview of the issues concluding treaties for the avoidance of double taxation and show what influence they can have on individual provisions of the cross-border effects of economic entities. I start from the hypothesis that the actual provisions of individual contracts can affect decision-making bodies, whether in the country to do business or not. In conclusion, this hypothesis is confirmed. The first chapter of this thesis deals with the taxation generally. Formulates double taxation in general, the various essential elements of taxation as subject to tax, the tax rate. It also deals with the sources of the Czech tax law, the emergence of double taxation and the method of its solution. This chapter also deals with tax crimes, i.e. tax havens, manipulation of transfer prices and freight handling. The second chapter focuses on agreements on avoidance of double taxation. It describes the OECD model treaty, the UN, including their development and highlights...
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