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Comparative analysis of double taxation of the income from employment in selected OECD countries
Mašatová, Julie ; Říhová, Lucie (advisor) ; Tepperová, Jana (referee)
The aim of this work is to evaluate the development of Article 15 Income from Employment of the OECD Model Tax Convention on Income and on Capital, especially with the accent on the Commentary of this article. Furthermore, to analyze, with the assistance of selected double tax treaties concluded by the Czech Republic, whether the Czech Republic, thus the Ministry of Finance, Ministry of Foreign Affairs and the General Directorate of Finance, follow the trend in the development of Model Tax Convention and apply it to the newly concluded double tax treaties, i.e. whether the institutions listed above accept the OECD Model Tax Convention and its Commentary as an interpretative regulation to be followed when concluding double tax treaties with both OECD member countries and with non-member countries.
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Benefits of an Offshore Company Establishment
Vlčková, Kateřina ; Filipová, Vladimíra (advisor) ; Drozen, František (referee)
These days, companies and individuals often look for opportunities that will bring them lower liability of paying taxes. Every year, there is a higher number of companies interested in tax havens. By setting up an offshore company in one of the tax havens, it is possible to reach lower corporate income tax rates, as most of the tax havens provide international companies with lower or zero rates on income taxes. However, low income taxes are not the only indicator that should convince companies to establish themselves in these countries. It is important to take additional costs into account. The objective of this thesis is to provide a primary overview of tax havens, their purpose, specifics of their usage and to find out under which circumstances they can be beneficial. With the help of a fictional company established in the Czech Republic, calculations of tax liability in various havens will be presented. Measured countries are Luxembourg, Cyprus, British Virgin Islands, Seychelles and Bermuda. On the basis of final calculations, conditions suited for offshore company establishment will be suggested.
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Daňové aspekty vzniku časově podmíněných stálých provozoven na území České Republiky
Kočí, Andrea
The diploma thesis deals with the problems of time threshold permanent establishment, i.e. service permanent establishment and permanent establishment from construction site. The main goal of thesis is to propose measures that could solve unclear tax aspects of constitution of time threshold permanent establishment in the Czech Republic. In the theoretical part of thesis is defined the term of "permanent estab-lishment" in Czech law on income tax, in article 5 of OECD Model tax convention and in Commentary on Article 5 of OECD Model tax convention. In the practical part of thesis is made the analysis of Article 5 of conventions for avoidance of double taxation, the analysis of practice of courts and the stance of Czech tax administrator on these problems. In the end of practical part are proposed measures that could solve unclear problems of time threshold permanent establishment.
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