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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 Heavens from Czech Republic Perspective
Zeman, David ; Hodinková, Monika (referee) ; Kopřiva, Jan (advisor)
In the theoretical part this work deals with the concept of tax havens, their distribution, use and selection. The second part compares three companies in the Czech Republic with a turnover of hundreds of thousands to several millions, and it demonstrates which for them would be advantageous or disadvantageous - to operate in the tax haven compared to staying in the Czech Republic.
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Profit shifting of European banks: Evidence from Global Reporting Initiative data
Sůva, Daniel ; Janský, Petr (advisor) ; Pavlova, Alena (referee)
This thesis investigates the profit shifting practices of European banks using country-by-country reporting data. The main contribution is the first use of Global Reporting Initiative reports by hand-collecting a sample of six banks. The thesis estimates the banks' effective tax rates in two ways, highlighting the advantages and limitations of each method. Additionally, the study com- pares the economic activity, employees, and tangible assets in tax havens and estimates multiple models to estimate the amount of shifted profits into tax havens. The analysis finds no significant connection between the effective tax rate of jurisdiction and booked profits, which is in contrast to a large body of existing literature. It concludes that the sampled banks do not systematically use tax havens but confirms a positive relationship between a bank's size and its participation in profit shifting. The thesis also highlights the correlation between tax transparency and lower tax avoidance among the sampled banks, which is in line with the hypothesis that increased transparency can increase tax revenue.
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Anti-Tax Avoidance Measures from the Perspective of Czech, European Union and International Tax Law
Kappel, Jiří ; Boháč, Radim (referee)
This dissertation deals with the issue of tax avoidance, which has been intensively discussed at international, EU and national level in recent years and has led to relatively extensive reforms of general and specific rules responding to this problem. For this reason, the main objective of this dissertation is to identify the impact of anti-avoidance rules that can be applied in the Czech Republic on the application practice, especially in the area of corporate income tax. With regard to the main objective of the dissertation, two hypotheses are formulated which will be examined, namely that I. these rules currently represent a sufficiently effective solution to tax avoidance and II. these rules do not contradict fundamental legal principles. As the rules under examination are not contained only in domestic law, the issue will also be approached from the perspective of EU and international law. Among the scientific methods, the thesis mainly uses description to introduce the individual rules, analysis to critically assess them and synthesis to formulate conclusions, verify hypotheses and propose related normative recommendations. Key words Tax Avoidance, GAAR, SAAR, BEPS
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Implementation of ATAD
Knetl, Štěpán ; Boháč, Radim (advisor) ; Vybíral, Roman (referee)
The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Directive (ATAD). It firstly introduces the problem of tax avoidance, its scale and defines basic concepts such as tax avoidance, tax evasion, tax havens and harmful preferential tax regimes. The author consequently describes origins of the Directive, OECD's Base Erosion and Profit Shifting Actions and other measures that are being implemented on the EU level such as international exchange of information in the field of taxation based on DAC Directives, the proposal of CCCTB. In the second chapter the ATAD is presented. It consists of five measures intended to neutralize the effects of tax avoidance practices, or in other words, to prevent erosion of the CIT base and the shifting of profits to jurisdictions enforcing little or no tax liabilities. First measure proposed is the interest limitation rule. It is intended to prevent the use of debt financing as a form of tax avoidance by limiting the amount of the tax-deductible borrowing costs that an entity is allowed to claim. Second measure is the exit taxation rule that requires the Member States to tax unrealised appreciation of assets based on the difference between amount equal to the market value of the transferred asset at the time of exit of the...
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Implementation of ATAD
Knetl, Štěpán ; Boháč, Radim (advisor) ; Vybíral, Roman (referee)
The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Directive (ATAD). It firstly introduces the problem of tax avoidance, its scale and defines basic concepts such as tax avoidance, tax evasion, tax havens and harmful preferential tax regimes. The author consequently describes origins of the Directive, OECD's Base Erosion and Profit Shifting Actions and other measures that are being implemented on the EU level such as international exchange of information in the field of taxation based on DAC Directives, the proposal of CCCTB. In the second chapter the ATAD is presented. It consists of five measures intended to neutralize the effects of tax avoidance practices, or in other words, to prevent erosion of the CIT base and the shifting of profits to jurisdictions enforcing little or no tax liabilities. First measure proposed is the interest limitation rule. It is intended to prevent the use of debt financing as a form of tax avoidance by limiting the amount of the tax-deductible borrowing costs that an entity is allowed to claim. Second measure is the exit taxation rule that requires the Member States to tax unrealised appreciation of assets based on the difference between amount equal to the market value of the transferred asset at the time of exit of the...
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Tax Heavens from Czech Republic Perspective
Zeman, David ; Hodinková, Monika (referee) ; Kopřiva, Jan (advisor)
In the theoretical part this work deals with the concept of tax havens, their distribution, use and selection. The second part compares three companies in the Czech Republic with a turnover of hundreds of thousands to several millions, and it demonstrates which for them would be advantageous or disadvantageous - to operate in the tax haven compared to staying in the Czech Republic.
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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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