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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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