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Analysis of Tax Havens in International Tax Planning
Bolf, David ; Klusáčková, Veronika (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis deals with the analysis of Tax Havens in the International Tax Planning. The thesis is divided into four parts. The first part is concerned with the internation tax planning. In the second part, the term tax havens is clarified together with the dilema of the bank secrecy, and the situation accrording to the fight against tax havens. The third part dedicates and analyses the tax havens in a detail view. The last part aims to analyse data and sorts tax havens into the categories by potentionallities of usage.
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Circumvention of the law, real contents of legal acts and the abuse of law in relation to tax planning
Horák, Milan ; Boháč, Radim (advisor) ; Kohajda, Michael (referee)
The purpose of my thesis is to analyze and characterize circumvention of the law, real content of legal acts and abuse of law in relation to tax planning. To combat tax abuse tax administrator has these three instruments available which in turn set limits of tax planning. The thesis is composed of four chapters. Chapter One differentiates between tax planning, tax abuse and tax evasion as different methods of lowering tax liability. Chapter Two consists of four subchapters, first three containing analysis and characteristic of circumvention of the law, real contents of legal acts and abuse of law. Each of these subchapters builds upon general definition which is then refined by case law of the Supreme Administrative Court and concludes with typical cases. The fourth subchapter deals with "tax evasion by other means" which some authors consider a similar instrument. The third chapter summarizes the current legislative state of these instruments and offers some thoughts de lege ferenda. The fourth chapter contains deeper analysis of the most important case law relating to individual instruments. Chapter Four should serve the reader as a reference while reading Chapter Two. Thesis illustrates the most typical cases of each individual instrument and concludes that the abuse of law doctrine is the most...
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Circumvention of the law, real contents of legal acts and the abuse of law in relation to tax planning
Horák, Milan ; Boháč, Radim (advisor) ; Kohajda, Michael (referee)
The purpose of my thesis is to analyze and characterize circumvention of the law, real content of legal acts and abuse of law in relation to tax planning. To combat tax abuse tax administrator has these three instruments available which in turn set limits of tax planning. The thesis is composed of four chapters. Chapter One differentiates between tax planning, tax abuse and tax evasion as different methods of lowering tax liability. Chapter Two consists of four subchapters, first three containing analysis and characteristic of circumvention of the law, real contents of legal acts and abuse of law. Each of these subchapters builds upon general definition which is then refined by case law of the Supreme Administrative Court and concludes with typical cases. The fourth subchapter deals with "tax evasion by other means" which some authors consider a similar instrument. The third chapter summarizes the current legislative state of these instruments and offers some thoughts de lege ferenda. The fourth chapter contains deeper analysis of the most important case law relating to individual instruments. Chapter Four should serve the reader as a reference while reading Chapter Two. Thesis illustrates the most typical cases of each individual instrument and concludes that the abuse of law doctrine is the most...
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Analysis of Tax Havens in International Tax Planning
Bolf, David ; Klusáčková, Veronika (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis deals with the analysis of Tax Havens in the International Tax Planning. The thesis is divided into four parts. The first part is concerned with the internation tax planning. In the second part, the term tax havens is clarified together with the dilema of the bank secrecy, and the situation accrording to the fight against tax havens. The third part dedicates and analyses the tax havens in a detail view. The last part aims to analyse data and sorts tax havens into the categories by potentionallities of usage.
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Tax Evasion and Transfer Pricing
Košťáková, Eliška ; Vítek, Leoš (advisor) ; Zídková, Hana (referee)
The aim of the diploma thesis is to answer the question of where is the line between tax evasion, tax avoidance and tax fraud. Furthermore to characterize methods of measurement tax evasion and introduced actions against tax evasion and tax avoidance at the national and international level. This aim is achieved through analytical and synthetic methods used from the first to third chapter of the diploma thesis. The main goal of diploma thesis is to use external sources of information to determining transfer pricing methods in small economic models. To achieve this goal is at first step explain the Arm's length principle, comparative analysis and subsequently introduced each transfer pricing method. The attention is also paid to assessment of each transfer pricing method with using analytical, synthetic and comparative methods.
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The actual content of legal acts in the tax law
Lívová, Jana ; Pelák, Jiří (advisor) ; Lišková, Vladimíra (referee)
This thesis deals with the real content of legal acts and its evaluation, identification and demonstration by the tax administrator. The aim is to determine which legal institutes are used in the tax administrator's control. Also if it uses the institute of the real content of legal acts and if it uses the correct way according to analysis of Czech law. The first part sets out the legal act, the second part sets out the interpretation of legal acts. The forms of the minimalization of the tax liability is set out in the third part, the greatest emphasis is on tax avoidance and tax evasion. The last part analyzes the most important law cases where the tax administrator argued one of the institutes simulated legal act, dissimulated legal act, evasion of the law, law abuse or tax avoidance by another method.
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Analysis of case law from the perspective of abuse or circumvention of the tax law
Růžičková, Tereza ; Kubátová, Květa (advisor) ; Schvábová, Andrea (referee)
Everyone seeks to minimize his tax liability. Generally, we can say that reducing the tax burden takes several forms. In this diploma thesis I deal with specific area - "tax avoidance", which is properly defined in the first chapter. Analysis and subsequent synthesis of the jurisprudence of the Supreme Administrative Court evaluates the current state of interpretation and usefulness of individual instruments by the tax authorities "correct" avoidant behavior of taxpayers. Interpretation of Czech courts is supplemented by a specific key court decisions of the European Court of Justice, defining the rules of one particular instrument. Finally, a Czech tax policy recommendation on the need for adaptation and mainly the general principle against tax avoidance in the Czech tax law could be found at the end of this thesis.
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