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HARMONIZATION OF TAXATION OF CORPORATIONS IN THE EU
Skalická, Hana ; Sadovský, Zdeněk (advisor)
After accession to the European Union, tax issues acquired and are still acquiring an entirely new character. A new legal environment is forming both in the Czech Republic and in the European Union. Until now, only indirect taxes have been harmonised, with direct taxes having remained in the domain of each member state. However, we are now feeling pressure to harmonise this area as well. Cases concerning value added tax belong to those that are now most often being resolved in front of the European Court of Justice in Luxembourg. Cases regarding direct taxes are also becoming increasingly important. Will direct taxes be harmonized to the same extent as indirect taxes have? When potential investor is considering his investment into a company, he needs to match comparable figures. Definitely, one of the most important criterions is the amount of profit after taxation followed by payout of dividends. If there are different ways of taxation of corporations in various EU Member States, then there would be no possibility to compare corporations placed in various EU Member States objectively. Therefore, the aim of this thesis is, based on the research in the whole EU regarding taxation of corporations, to suggest a method how to harmonize taxation of corporations, which now prevents companies from trading in a single EU market, and also to minimize corporation’s costs of fulfilment of tax administration requirements of each Member State. This aim has been achieved through the following partial aims: .. An analysis of taxation of corporations in each of all 27 EU Member States, .. An analysis of proposals of the European Commission regarding harmonisation of taxation of companies, .. Suggestion of own method of harmonization of taxation of corporations in the EU. In conclusion, there are emphasized the contributions of this thesis to the science, to the practice and to education.
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HARMONIZATION OF TAXATION OF CORPORATIONS IN THE EU
Skalická, Hana ; Sadovský, Zdeněk (advisor)
After accession to the European Union, tax issues acquired and are still acquiring an entirely new character. A new legal environment is forming both in the Czech Republic and in the European Union. Until now, only indirect taxes have been harmonised, with direct taxes having remained in the domain of each member state. However, we are now feeling pressure to harmonise this area as well. Cases concerning value added tax belong to those that are now most often being resolved in front of the European Court of Justice in Luxembourg. Cases regarding direct taxes are also becoming increasingly important. Will direct taxes be harmonized to the same extent as indirect taxes have? When potential investor is considering his investment into a company, he needs to match comparable figures. Definitely, one of the most important criterions is the amount of profit after taxation followed by payout of dividends. If there are different ways of taxation of corporations in various EU Member States, then there would be no possibility to compare corporations placed in various EU Member States objectively. Therefore, the aim of this thesis is, based on the research in the whole EU regarding taxation of corporations, to suggest a method how to harmonize taxation of corporations, which now prevents companies from trading in a single EU market, and also to minimize corporation’s costs of fulfilment of tax administration requirements of each Member State. This aim has been achieved through the following partial aims: .. An analysis of taxation of corporations in each of all 27 EU Member States, .. An analysis of proposals of the European Commission regarding harmonisation of taxation of companies, .. Suggestion of own method of harmonization of taxation of corporations in the EU. In conclusion, there are emphasized the contributions of this thesis to the science, to the practice and to education.
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Taxation of corporate incomes in Austria
Milotová, Michaela ; Láchová, Lenka (advisor) ; Matějka, Václav (referee)
This thesis deals with corporate income tax in Austria. The aim of this thesis is to analyse the construction of corporate income tax in Austria into the details and identify good elements suitable for the application into the Czech juridical system. The first chapter is focused on GDP/tax revenues ration and its composition. Next chapter describes briefly theoretical attitudes to the corporate income tax. The main part of this thesis is contained in the chapter no. 3, which is focused on particular construction elements of this tax. There are also examples of taxation of two model corporations incorporated in Czech Republic and Austria in there. Next two chapters are focused on taxation in international context and on transactions with related parties. The last chapter identifies positive as well as negative elements of CIT in Austria and suggests recommendations for the Czech Republic. It recommends particularly reduction of interest expenses paid to the companies incorporated in tax heavens and the possibility of group taxation.
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Analysis of applicability and transferability of the corporation tax losses within the EU
Fuksová, Barbara ; Říhová, Lucie (advisor) ; Vančurová, Alena (referee)
This thesis analyses the treatment of tax losses in the Czech Republic in national and cross-border situations in the context of the recommendations of the European Commission and trends in treatment of losses, based on the cases of the European Court of Justice. Lack of immediate relief for losses leads to asymmetry of taxation, which is one of the causes of limitation functioning of the EU internal market. The comparison with other EU Member States based Czech Republic as a country with below-average possibilities of obtaining relief for losses. These include the 8 Member States have not yet adopted any national system of group taxation. Ways to get immediate relief for losses in domestic situations, including remains fiscally transparent entities in the group structure. Cross-border loss relief is available only if doing business in certain countries either by means of transparent entities or permanent establishments. This method of obtaining relief for losses is contrary to the interpretation of freedom of establishment, according to which there should be no discrimination on the basis of the legal form of business.
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