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International Taxation of Incomes Received from Austria
Slámová, Klára ; Říha, Pavel (referee) ; Brychta, Karel (advisor)
This bachelor´s thesis deals with the tax liability of a taxpayer, a tax resident of the Czech Republic, which both receive income from sources in our country, as well as from Austria. The bachelor´s thesis analyzes the avoidance of double taxation with Austria in order to propose a methodology to taxation income through model examples. Practical part is focused on income from employment.
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Application of the Convention between the Czech Republic and the Republic of Austria for Avoidance of Double Taxation
Přechová, Renáta ; Šnajdrová, Jana (referee) ; Brychta, Karel (advisor)
The present thesis deals with the articles of the double taxation agreement concluded between the Czech Republic and the Republic of Austria. Its aim is to highlight the solution of problems concerning the jurisdiction in the state of source and the jurisdiction in the state of residence. It shows how the methods to prevent double taxation are to be applied. It compares the differences in tax obligation of a resident of a country with which the Czech Republic has not concluded an agreement on precluding double taxation with the obligation of a resident of the Republic of Austria, which is a contracting country. It proves the justification of the existence of agreements on precluding double taxation by means of concrete examples and points out the necessity of their continual updating.
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International and domestic aspects of double taxation
Ferková, Marianna ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
This diploma thesis deals with different aspects of international and domestic double taxation. Within international double taxation short treatise about national legislation related to double taxation is followed by the longer part dedicated on the tax conventions on income and capital which are the most effective instrument in the field of double taxation elimination. Then the negotiation process and their place in czech domestic legislation is described. One part focuses on the role played by European union in direct tax adjustment. Part about residence determinig (both individuals and companies) in case of existence of the tax convention and in case of its absence follows. Unilateral, multilateral and bilateral measures especially are desribed. As the example to illustrate the impact of different methods used to eliminate double taxation on tax is given practical calculation. Double taxation elimination procedure is explained on the concrete kind of income (dividends) at the end of the international double taxation charter. Within domestic double taxation its causes and kinds are desribed. Finally, last part looks at current and forthcoming czech legislation related to economical domestic double taxation.
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Mezinárodní zdaňování pasivních příjmů v judikatuře Soudního dvora Evropské unie
Bělušová, Kristýna
Tento článek se zabývá mezinárodním zdaňování pasivních příjmů, resp. dividend v návaznosti na judikaturu Soudního dvora Evropské unie. Záměrem článku je identifikovat některé problematické otázky mezinárodního zdaňování dividend v rámci Evropské unie na základě analýzy rozsudků Soudního dvora Evropské unie a v návaznosti na uvedené vyhodnotit obecná pravidla ohledně vnitrostátní právní úpravy tak, aby nedocházelo k porušení svobody usazování dle článku 49 Smlouvy o fungování Evropské unie a volného pohybu kapitálu dle článku 63 Smlouvy o fungování Evropské unie, což vede k zajištění fungování jednotného vnitřního trhu Evropské unie.
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International and domestic aspects of double taxation
Ferková, Marianna ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
This diploma thesis deals with different aspects of international and domestic double taxation. Within international double taxation short treatise about national legislation related to double taxation is followed by the longer part dedicated on the tax conventions on income and capital which are the most effective instrument in the field of double taxation elimination. Then the negotiation process and their place in czech domestic legislation is described. One part focuses on the role played by European union in direct tax adjustment. Part about residence determinig (both individuals and companies) in case of existence of the tax convention and in case of its absence follows. Unilateral, multilateral and bilateral measures especially are desribed. As the example to illustrate the impact of different methods used to eliminate double taxation on tax is given practical calculation. Double taxation elimination procedure is explained on the concrete kind of income (dividends) at the end of the international double taxation charter. Within domestic double taxation its causes and kinds are desribed. Finally, last part looks at current and forthcoming czech legislation related to economical domestic double taxation.
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Application of the Convention between the Czech Republic and the Republic of Austria for Avoidance of Double Taxation
Přechová, Renáta ; Šnajdrová, Jana (referee) ; Brychta, Karel (advisor)
The present thesis deals with the articles of the double taxation agreement concluded between the Czech Republic and the Republic of Austria. Its aim is to highlight the solution of problems concerning the jurisdiction in the state of source and the jurisdiction in the state of residence. It shows how the methods to prevent double taxation are to be applied. It compares the differences in tax obligation of a resident of a country with which the Czech Republic has not concluded an agreement on precluding double taxation with the obligation of a resident of the Republic of Austria, which is a contracting country. It proves the justification of the existence of agreements on precluding double taxation by means of concrete examples and points out the necessity of their continual updating.
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International Taxation of Incomes Received from Austria
Slámová, Klára ; Říha, Pavel (referee) ; Brychta, Karel (advisor)
This bachelor´s thesis deals with the tax liability of a taxpayer, a tax resident of the Czech Republic, which both receive income from sources in our country, as well as from Austria. The bachelor´s thesis analyzes the avoidance of double taxation with Austria in order to propose a methodology to taxation income through model examples. Practical part is focused on income from employment.
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