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Corporate tax harmonisation under the EU law
Nymburský, Ondřej ; Vondráčková, Aneta (advisor) ; Tomášek, Michal (referee)
Corporate Tax Harmonisation under the EU Law Abstract in English language The diploma thesis focuses on the corporate tax harmonisation from the perspective of European law; in particular it analyses selected aspects of common system of taxation applicable to parent and subsidiary companies, common system of taxation applicable to interest and royalty payments and the Anti-Tax Avoidance Directive (ATAD). Its aim is to analyse selected secondary legislation de lege lata in the light of the judicial practice of the Court of Justice of the European Union as well as related issues arising under the primary legislation, including the limits of competences. The thesis consists of the introduction, four chapters and the conclusion. The first chapter deals with theoretical introduction to the taxation terminology and stages of tax cooperation between tax jurisdiction, i.e. coordination, aproximation and harmonisation, together with tax competition. In the second chapter, the reader is acquainted with the harmonisation process of direct taxation and its legal basis under the Treaty on the Functioning of the European Union and primary legislation limits. The third chapter is fundamental as it focuses on comprehensive analysis of selected secondary legislation, while presenting and analysing the case law of the Court...
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