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Corporate income tax deductibility of interest after the implementation of ATAD
Vicherek, Ondřej ; Boháč, Radim (advisor) ; Vybíral, Roman (referee)
Corporate income tax deductibility of interest after the implementation of ATAD Over the past few years, the media and the general public have focused heavily on tax avoidance of large corporations such as Apple and Google. OECD (2012) issued BEPS report in which it described tax base erosion and profit shifting methods. The tools described therein include also excessive use of foreign capital and the associated tax shield. The regulations and recommendations as set out in the BEPS report were implemented in the European ATAD Directive in 2016. This thesis focuses on the limitation of deductibility of interest, especially from the perspective of the analysis of the Czech implementation with regard to the regulation set out in the BEPS report and the ATAD Directive and fulfillment of their objectives. The main goal of the thesis is to assess the fulfillment of the objectives set out in the BEPS report and in the ATAD Directive within their Czech transposition, to analyze the Czech regulation and to point out possible shortcomings of the Czech regulation and problems related to the implementation of new rules limiting the deductibility of borrowing costs. The thesis is divided into four chapters. The first chapter focuses on the problematics of interest and other borrowing costs deductibility,...
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EU's Measures Against Income Tax Optimalisation
Hortíková, Kateřina ; Tepperová, Jana (advisor) ; Tecl, Jan (referee)
This diploma thesis provides an analysis of the Anti-Tax Avoidance Package (ATAP) proposed by European Union. This package was adopted in relation to OECD's Base Erosion and Profit Shifting (BEPS) project. It consists of measures that aim to reduce the level of tax avoidance caused mainly by base erosion and profit shifting within multinational corporations. The theoretical part of the thesis consists of brief introduction of the BEPS project, followed by detailed analysis of the EU package. The practical part tends to analyse the possible impact of the package implementation in Czech Republic on selected measure, tax limitation of paid interests deductibility. Real data of three Czech companies were used for the analysis. The author used the method of a case study to compare tax impacts of current thin capitalisation rule application against the proposed rule limiting the interest deductibility up to 30 % of EBITDA.
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Daňová uznatelnost finančních nákladů
Rydlová, Gabriela
This thesis deals with the tax deductibility of financial expenses, which amount is determined by tests of tax deductibility of expenses from lending financial instru-ments. On the example of a real company are two tax periods applying these tests. Based on results are proposed recommendations. In the case of distribution prof-its to abroad is applied a specific contract of prevention of double taxation.
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Thin capitalisation in Czech Republic
Flaška, Ondrej ; Francírek, František (advisor) ; Roun, Vlastimil (referee)
This diploma thesis deals with thin capitalisation rules in the Czech Republic. The main objective is to analyze tax-deductibility of financial costs connected with loans from related parties. Czech Republic has been member of EU since 2004. The EU membership established the responsibility for Czech Republic to approximate national legislation of taxation with EU law, so the second objective of the diploma thesis is to consider how the Czech Republic deals with harmonisation of tax-deductible financial cost connected with loans from related parties.
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Transformation of the income trading to the tax base
Svobodová, Pavla ; Müllerová, Libuše (advisor) ; Černý, Václav (referee)
The graduation theses solves the interrealationsship and the differences between the income trading and the tax base. There are described and practically documented the adjustments that are necessary within the transformation. Of these adjustments there is in more detail described the depreciation of the fixed assets and the adjustments to the trade receivables. There is solved the impact of the error correction in the accounting to the tax base too. The significant part of this theses solves the problem of the thin capitalization. This problem is analysed with the view of the rigor juris in the tax period of 2008,2009 and 2010
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Tax aspects of Holding Law
Michalíková, Jana ; Marková, Hana (advisor) ; Tůmová, Jaroslava (referee)
Práce je sumarizací jednotlivých institutů týkajících se koncernů v daňovém právu, objasňuje jejich význam a účel a zároveň na několika postřezích z praxe ukazuje jejich skutečné praktické dopady. Zhodnocuje právní úpravu koncernů z daňového hlediska a poskytuje načrtnutí možného dalšího vývoje této oblasti finančního práva. Daňová úprava koncernů je podrobněji analyzována z hlediska transakcí v rámci koncernů, příjmů a výdajů souvisejících s koncerny i oblasti daně z přidané hodnoty.
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