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Tax and Related Effects of Business of Czech Entities in Austria
Vařílková, Simona ; Antošová, Lucie (referee) ; Kopřiva, Jan (advisor)
The diploma thesis deals with the tax effects on Czech entities carrying out economic activities in Austria. The theoretical part of thesis focuses on the definition of basic concepts of tax issues, description of the tax system in the selcted country. Furthermore, the theoretical part covers the principles of the double taxation treaty between the Czech Republic and Austria. The practical part is dedicted to model examples of Czech entities doing business or working in Austria.
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Cross-border aspects of corporate taxation
Laouici, Said ; Kotáb, Petr (advisor) ; Tuláček, Michal (referee)
- 1 - Cross-border aspects of corporate taxation Abstract This thesis addresses the key challenges, institutions, and current challenges in the cross- border taxation of concerns, which are better known as multinational companies. Multinational companies are business associations that must achieve the quality to be described as concerns, which are the focus of this thesis. The essential aspects in the cross-border taxation of a concern are the existence of double taxation or non-taxation, the transfer pricing and, finally, the new institutes that are aimed at reacting to the most recent and unsolved issues in this area. These are still numerous, but the efforts of countries and multinational organisations to tackle them are very strong. Specifically, this thesis deals with the essential instruments in the field of international taxation, such as double taxation treaties, transfer pricing, which can be described as traditional institutes, but also new institutes in the field of international taxation, which are BEPS action plans (Pillar I and Pillar II), MLI, EU directives, which compete with the basic and new instruments. The BEPS Action Plans and their impact are continuously reflected in each chapter of this thesis. The thesis also deals with tax competition, coordination, and harmonisation relationships...
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Taxation of Incomes arising from the Construction Contract realized in Slovakia
Minář, Michal ; Kučera, František (referee) ; Brychta, Karel (advisor)
This diploma thesis deals with the obligations for implementing the construction project in the Slovakia and its taxation. At first is defined basic terminology, concept of single market of the European Union and the harmonization process of direct and indirect taxation. In the analytical part of the thesis are relevant sources of international, union and national law analyzed. The practical part is focused on specification construction contract, accomplishment all obligations and an exemplary taxpayer's tax liability is calculated.
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Tax Havens and their Utilization
Malý, Jiří ; Krejčí, Stanislav (referee) ; Kopřiva, Jan (advisor)
Master thesis deals with tax havens and their utilization. In the teoretical part are defined fundaments of the tax havens and their utilization. Next part of thesis is analysis of tax havens in the Middle East. In this part focus is on coutries like Bahrain, Qatar or United Arab Emirates. Based of founded facts are concluded recommendations for concrete company with aim to reduce taxation.
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Optimization of Tax Burden of a Concern
Zvěřinová, Pavlína ; Nekulová, Ivana (referee) ; Kopřiva, Jan (advisor)
The master's thesis deals with the optimization of the tax burden of a concern based in the Czech Republic, which receives income from abroad. Optimization should be achieved through a change of the subsidiary's head office. Another proposal is a creation of a permanent establishment abroad. The output of the work is to decide on the most suitable structure of the concern in terms of head office and the number of its companies. The decision will be made on the basis of a comparison of the results of tax obligations calculated according to the legislation of the proposed countries and the related tax levies. The diploma thesis is focused on corporate income taxation, as the subjects of the group are limited liability companies. This issue will be explained theoretically on the basis of professional literature and practically using a comprehensive example.
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Tax Havens and Their Use
Komárková, Renata ; Filipová, Vladimíra (referee) ; Kopřiva, Jan (advisor)
This master thesis deals with the characteristics of tax havens, approach beneficiary companies and way of their use and potential abuse. The first part defines basic terms, which are tax havens are closely linked. The second part is devoted to the characterization chosen tax havens in different areas of model-based taxation example of two types of companies. The third part contains the suggestions and recommendations for setting up a company in a tax haven.
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Tax Havens and their Utilization
Koubek, Pavel ; Melková,, Izabela (referee) ; Kopřiva, Jan (advisor)
The master´s thesis is focused on the characteristic of tax havens and their possible utilization. On the basis of the literature in the theoretical part there are described the basic assumptions of international tax planning, agreements for the avoidance of double taxation and tax havens. Analytical part describes selected tax havens. The practical part of the thesis deals with the possibilities of tax optimalization through the utilization of tax havens.
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Taxation of Permanent Establishment in the Czech Republic
Abrahamová, Eva ; Koumal, Marek (referee) ; Brychta, Karel (advisor)
Master´s thesis deals with issue of taxation of permanent establishment which come into existence to the resident of a Contracting State on the grounds of construction site in the Czech Republic. The thesis contains an analysis of relevant articles of the double tax treaty with Slovakia and relevant legal regulations of the Czech republic, on the basis of which is proposed the methodology for determining the tax base of the permanent establishment in the Czech Republic.
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