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Double taxation treaties with particular regard to the concept of a permanent establishment
 Kubeš, Jan ; Vybíral, Roman (advisor) ; Sejkora, Tomáš (referee)
01 Double tax treaties aim to prevent double taxation. Double taxation of income is an undesirable phenomenon from the taxpayers' point of view. The most widespread way of preventing it is through bilateral agreements concluded between states under the OECD Model Agreement. In general, a prerequisite of taxation is either tax residency or the existence of a permanent establishment, which can take various forms. Double taxation treaties and the concept of a permanent establishment in which this master thesis is dedicated, have undergone a dynamic transformation over the past few years due to both Base Erosion and Profit Shifting reports (BEPS) and the Multilateral Instrument by OECD (MLI). This transformation is demonstrated in this thesis by comparing selected provisions of the OECD Model Agreement 2014 and 2017. This thesis addresses the current question of whether the current development of tax treaties is to avoid double taxation or avoid double non-taxation and artificial tax reduction. Double tax treaties, as practice shows, fulfill their traditional role. The first chapter deals with the system of national and international taxation in general. The second chapter deals with the issue of double taxation, methods of its avoidance and comparison of versions of the OECD Model Agreement 2014 and 2017. The...
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