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Tax aspects of the distribution of profit
Ivanova, Elena ; Vítek, Leoš (advisor) ; Moravcová, Jana (referee)
The thesis focuses on the the distribution of profit from a tax perspective. The aim of the thesis is to determine how different tax conditions of distributed profit affect the taxpayer's tax burden. For the purpose of achieving the aim of this thesis the comparison of selected test cases of the distribution of profit was made. The thesis analyse the law conditions for distribution of profit in the legal system of the Czech Republic and the rules for the assessment of this area in the international context. The thesis is devoted to methods of avoiding double taxation at the national level and the international level.
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Double Tax Treaties
Procházková, Andrea ; Černohlávková, Eva (advisor) ; Marková, Michaela (referee)
The thesis deals with issue of international double taxation with respect to taxes on income and capital. The aim of the thesis is to provide a comprehensive overview of the issue of concluding international double tax treaties and to verify, whether the differences in their provisions can be significant enough to affect activities of internationally active entities. The body of the thesis is divided into three chapters. The first chapter explains what double taxation is, how it occurs and the possible ways of its elimination. It also deals with related tax evasion. The second chapter is devoted to bilateral and multilateral tax treates. The emphasis is on OECD and UN model conventions and related issues of exchange of information, non-discrimination and dispute resolution. The third chapter focuses on the approach of the Czech republic to enter into tax treaties. Its main part is devoted to a comparison of tax treaties which the Czech republic has concluded with the United States of America, Slovakia and Germany.
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The importance of international treaties on the Avoidance of Double Taxation in international business
Hollovičová, Tereza ; Klosová, Anna (advisor) ; Gullová, Soňa (referee)
This thesis addresses the impact of international agreements on avoidance of double taxation on international business. The aim of the bachelor thesis is to analyze the specific bilateral agreements on avoidance of double taxation concluded by the Czech Republic and to assess their consistency, scope and up-to-dateness in international trade cooperation. These findings are obtained using the method of comparison of specific bilateral agreements concluded between the Czech Republic and the Federal Republic of Germany, the United States and the Republic of China. The practical part illustrates the real use of international treaties on avoidance of double taxation on income from foreign investments and demonstrates their importance for the development and regulation of international trade relations.
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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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Current questions of income tax (double dividend taxation)
Kouba, Stanislav ; Vítek, Leoš (advisor) ; Klazar, Stanislav (referee)
This thesis deals with the topic which si common called double dividend taxation or double taxation of corporations. It is very current topic in Czech republic in this time beacause since 1 January 2015 there is amendment of income tax code which completely changes the dividend taxation. This change can be evaluated as a one of the most progresive changes since 1989 in area of income taxation in Czech republic. This thesis will not only evaluate this change, but it will evaluate more variants of solving the problems with double taxation. The target of thesis is to find the best solution between theoretic and practicly used solutions. The next target is the analysis of these solutions from their material and procedure aspects.
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Aspects of taxation when entering foreign markets
Berková, Hana ; Černohlávková, Eva (advisor) ; Marková, Michaela (referee)
This diploma thesis analyzes several aspects of taxation when entering a foreign market. The first chapter explains the difference between nominal and effective tax rates and tax burden regulation by enterprises during the current debt crisis. The second chapter deals with double taxation agreements and methods that eliminate double taxation. The third chapter describes the rules of transfer pricing and advance pricing agreements. The last chapter focuses on tax incentives and risks of taxation, especially tax avoidance, tax evasion and the negative attitude of developed countries against tax havens.
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Methods to avoid double taxation of dividends in the EU countries
Borzova, Ekaterina ; Kubátová, Květa (advisor) ; Hartlová, Alena (referee)
My thesis is concentrated on double taxation issues in European Union countries. Target is to describe various systems of dividends taxation in different EU countries and compare them with system that Czech Republic uses, to evaluate how effectively are double taxation eliminated based on the double taxation treaties. Efficiency of double taxation avoidance is measured by calculation of value "overtaxation". In the theoretical part of the thesis are the term double taxation defined and the reasons of their source and methods of their elimination are mentioned. Practical part is dedicated to comparison how the different countries are handling with dividends taxation in their domestic legislation and furthermore the ways of dividends taxation in their double taxation treaties are explained. In the conclusion of the thesis are the topics for the practice given, and the actual tax system of Czech Republic development is described.
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The Implementation of the European Union directives relating to dividend taxation focusing on the Czech republic
Miklová, Alena ; Vančurová, Alena (advisor) ; Doležalová, Ivana (referee)
This thesis deals with the issue of dividend taxation in the European Union. Dividends are subject to double taxation, which constitutes an obstacle to the single internal market. To remove this obstacle the Parent -- Subsidiary Directive 90/435/EEC was adopted (hereinafter "Directive"). In the thesis I described the implementation in selected European Union countries and the issues that contributed to a better functioning of the internal market and whether there are further obstacles it the internal market. I mentioned also the current harmonization steps of the institutions of the European Union. Comparative analysis of the tax treatment of selected Member States showed that there are still situations in which national legislation can come into conflict with the Directive. However, I found by calculating the effective tax rate on dividends paid from the Czech Republic to selected countries that the implementation of the Directive has contributed to a better functioning of the internal market.
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Accounting and tax aspects of different types of the foreign market entrance
Peciválová, Lenka ; Pelák, Jiří (advisor) ; Mezerová, Jana (referee)
The major topic of this thesis is tax and accounting aspects of different types of foreign market entrance. Basic types of foreign market entrance and their accounting and tax comprehension are defined in the first chapter. The second chapter is focused on legal point of view of the foreign entities business in Czech Republic and there are defined the main differences in foreign entities business by czech corporate entity and branch. The main differences of these subjects from the tax point of view are established in the third chapter, tax registration, tax duty origin, tax base, double taxation, mutual relations and transfer pricing. The fourth chapter is focused on the accounting duties both subjects, their differences and transactions accounting in practice of branch and its founder, foreign entity, in centralized and separated accounting system.
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Taxation of income from securities in the Czech Republic and the European context
Cvetanova, Lilia ; Vančurová, Alena (advisor) ; Jelínek, Michal (referee)
This Thesis describes the manner and the rate of the taxation of revenue floating from securities to individuals. The Thesis covers this kind of taxation in the Czech Republic and certain European countries. The aim of this paper is also the comparison of the effective tax rates of the yields floating from shares and bonds in different European states. The first part contains basic information about securities as an institute and basic characteristics of shares and bonds as defined by the Czech legislature. The second part deals with the two Czech income taxes and the question of double taxation. The third part is dedicated to certain aspects of international tax conventions concerned with the topic. The last part describes the ways that European countries use to tax revenues of individuals from shares and bonds. Also it compares the effective tax rates that apply on these revenues. There is also a description of the situation when Czech tax residents do tax their income from foreign sources in the Czech Republic.
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