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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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Methods of double taxation avoidance and using thereof in the Czech tax law
Turek, Petr ; Kotáb, Petr (advisor) ; Kohajda, Michael (referee)
83 RESUMÉ Methods of double taxation avoidance and using thereof in the Czech tax law The Master Thesis deals with the methods of international double taxation avoidance as they are set out by the OECD (Organisation for Economic Co-operation and Development) and UN (United Nations) Model Conventions, as well as by the international bilateral treaties concluded by the Czech Republic based on these model conventions. The definition of the basic terms used by the Czech tax law is first set out by the Thesis. Then later the Thesis focuses on the two fundamental model conventions being the OECD model and the UN model, on the "model" treaty concluded by the United States of America, and on the double taxation avoidance international treaties in general - their role, reasons and possible use. The European law regarding the international double taxation shall also be mentioned, i.e. directives of the European Union, decisions of the Court of Justice of the European Union, or eventually the other initiatives brought up at the European Union bases. The fundamental part of the Thesis regards the methods of the double taxation avoidance: the exemption method and the credit method, including their types. Each of the mentioned methods (full exemption, exemption with progression, full credit and ordinary credit) is...
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