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Tax and social security systems in selected EU countries
Vágnerová, Pavlína ; Tepperová, Jana (advisor) ; Čejková, Eliška (referee)
The aim of this master thesis is the comparison of selected elements of the tax and social security systems in the Czech Republic, Slovakia, Austria and Germany, which are related to employees and employers and it is counted with them in model examples, then evaluation of advantages and disadvantages of employees´ migration under the structure of posting between the Czech Republic and other countries and finally the comparison of employees´ incomes after receiving benefits from social security system of each country (especially old age pension and parental allowance). In the first part of the thesis there is explained problematics of double tax treaties and EU coordination of social security. Then there is the comparison of above mentioned elements of the tax and social security systems in each country. In the last part I apply findings on model employees and I make a conclusion from amount of their net incomes. Migration to another EU member country is the most profitable for employee who is subjected to taxation in other EU countries but he remains under the Czech social security system. In terms of social benefits, retired people are supported the most in Austria and families with children in Germany.
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Concept of International Taxation of Permanent Establishments
Sladkovský, Otakar ; Tepperová, Jana (advisor) ; Tecl, Jan (referee)
The diploma thesis deals with the concept of International Taxation of Permanent Establishments. The treatment of permanent establishment is defined and compared from both czech and international perspective. Furthermore, there are identified issues that individual countries and the international organization OECD have to deal with under the Action Plan BEPS. Moreover, at the end of the thesis frequency of permanent establishments in the Czech Republic is displayed according to the residence of taxpayers.
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Application problems of taxation of royalties in Czech Republic
Hrbáčková, Tereza ; Vančurová, Alena (advisor) ; Doležalová, Ivana (referee)
This thesis deals with application issues of taxation of royalties on example of a company engaged in international trade with footwear and clothing. It shows how to aply taxes on the royalty paid between subsidiary located in the Czech Republic and the parent company based in Great Britain, on the basis of the license agreement. The work is a legal analysis of legislative sources and comparative analysis of Article 12 royalties in double taxation conventions concluded between the Czech Republic and OECD member countries.
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Comparative analysis of the taxation of royalties folowing between the Czech Republic and other member states of EU
Štecherová, Eliška ; Kubátová, Květa (advisor) ; Říhová, Lucie (referee)
This thesis deals with the question of how far the Member States of EU have unified the system of taxation of royalties with respect to the Czech Republic. This issue is analyzed on the basis of comparison of Conventions between Czech Republic and other member states of EU. As key comparators were used the following approaches: grammatical interpretation of conventions, the definition of royalties and the range of taxation in the state of source. In order to examine the issue of taxation of royalties, attention is also given to the definition of royalties from the Czech legislation as well as from OECD (based on the Commentary to the Model Treaty) point of view. The thesis outlines also practical approaches to taxation of royalties in various model situations.
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