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Methods of Investment in International Private Law
Štaňko, Andrej ; Pauknerová, Monika (advisor) ; Balaš, Vladimír (referee) ; Poláček, Bohumil (referee)
Methods of Investment in International Private Law Dissertation thesis is structured into 9 Sections. First section deals with reasons why entrepreneurs use international holdings: regulative, questions of taxation and legal system reasons. Second section describes legal sources applicable for the analyzed issues. Third section summarizes some of the risks relating to use of international holding companies, namely risk of breaching the criminal law or circumventing other legal rules. Apart from legal risks, there are economic risks to be mitigated. The risks mentioned are systematic risk (e.g., bankruptcy of the state) and personal risk relating to the foreign managers (incompetency, fraud). Fifth section deals with typical transactions in the group of companies relating to financing by banks and bods issuance. Briefly analyzed are also acquisition structures and whitewash procedure. Sixth and seventh section describe tax burdens in the Czech republic, Cyprus, Seychelles, Mauritius and number of other countries. Analysis of the jurisdictions in nine countries as to the recognition and enforcement of foreign judicial decisions is provided in the section eight. The dissertation thesis is concluded with description of the civil law applicable after the so called recodification planned in the Czech...
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The tax system and agreements on the avoidance of double taxation
Kohoutová, Petra ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
1 Abstract: The tax system and agreements on the avoidance of double taxation This diploma thesis "The tax system and agreements on the avoidance of double taxation" is focused on practical issues in the field of using international corporate structure in order to decrease the tax liability applicable on entrepreneurs. The diploma thesis includes the basic description of the legal rules applicable in the Czech Republic, such as acts and also international treaties. In the field of EU law, the diploma thesis described briefly EU directives based on which it is possible to transfer dividends, interest and royalties between mother and daughter companies without withholding tax payable in the Czech Republic. International treaties described in this diploma thesis were double taxation avoidance treaties between the Czech Republic and Cyprus and between Cyprus and Seychelles. First part of the diploma thesis is describing legal regulation of income taxes applicable in the Czech Republic. It is aimed mainly on interests, dividends and royalties. The first part of the diploma thesis is of theoretical nature which gives basics for the second and third part which practically analyze possibilities to decrease tax burdens of entrepreneurs. Second part of the diploma thesis brings analysis of individual model situations...
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