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Theoretical aspects of tax avoidance in the field of income taxes
Šmirausová, Petra ; Marková, Hana (referee)
1 Theoretical aspects of tax avoidance in the field of income taxes Abstract in English The dissertation deals with the theoretical aspects of the controlled foreign company rules (CFC rules), which are the transposition of the Council Directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market (ATA Directive). It focuses on current issues of compliance of the Czech CFC rules with double tax treaties and with primary EU law, as well as the question of the ability of this legislation to achieve its purpose, which is to prevent tax avoidance. The purpose of the dissertation is to join the doctrinal discussion of conceptual problems associated with the CFC rules and at the same time to present conclusions that will enable the Czech tax policy makers to better deal with the legislation of this measure and achieve greater legal certainty in implementation of this measure. The argumentation presented in this dissertation leads to several theoretical and practical conclusions. First, it points to the fact that the Czech CFC rules are not entirely able to achieve its purpose and thus to prevent tax evasion. This dissertation identifies reasons of this problem which are (i) the scope of the CFC rules, which is not wide enough to cover all actions that are...
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Usage possibilities of the cloud products of satellite datasets
Šácha, Petr
Title Usage possibilities of the cloud products of satellite datasets Author: Bc. Petr Šácha Department: Department of Meteorology and Environment Protection Supervisor: RNDr. Petr Pišoft Ph.D. Supervisor's e-mail address: Petr.Pisoft@mff.cuni.cz Abstract: Cloudiness plays an important role in the global energy and water cycle. In particular, the presence of clouds dominates the planetary albedo and takes part in many climate feedback processes. In this thesis a short informational overview of remote sensing, a description of EUMETSAT, satellites, which it used, its part CM- SAF and a search retrieval of current research is given at first. Then the study is focused on the cloud satellite products, especially on CFC (cloud fractional cover) and CTY (cloud type) products. Data sets of daily averages of these products are compared with the daily averages created from the surface SYNOP observations of the total cloud cover and cloud type in the area of the Czech Republic. In the case of big variances between the two examined datasets of daily averaged cloud coverage, possible causes like the sampling error, dependence on season, localization of the station and the elevation and type of cloudiness, are searched. Several statistic analyses and validation scores are computed. Finally, possibilities of the examined...
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Usage possibilities of the cloud products of satellite datasets
Šácha, Petr
Title Usage possibilities of the cloud products of satellite datasets Author: Bc. Petr Šácha Department: Department of Meteorology and Environment Protection Supervisor: RNDr. Petr Pišoft Ph.D. Supervisor's e-mail address: Petr.Pisoft@mff.cuni.cz Abstract: Cloudiness plays an important role in the global energy and water cycle. In particular, the presence of clouds dominates the planetary albedo and takes part in many climate feedback processes. In this thesis a short informational overview of remote sensing, a description of EUMETSAT, satellites, which it used, its part CM- SAF and a search retrieval of current research is given at first. Then the study is focused on the cloud satellite products, especially on CFC (cloud fractional cover) and CTY (cloud type) products. Data sets of daily averages of these products are compared with the daily averages created from the surface SYNOP observations of the total cloud cover and cloud type in the area of the Czech Republic. In the case of big variances between the two examined datasets of daily averaged cloud coverage, possible causes like the sampling error, dependence on season, localization of the station and the elevation and type of cloudiness, are searched. Several statistic analyses and validation scores are computed. Finally, possibilities of the examined...
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