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Taxation of Czech Tax Resident with Incomes from the Great Britain
Nováková, Kateřina ; Čížek, Daniel (referee) ; Brychta, Karel (advisor)
This thesis deals with international taxation of individuals in the Czech Republic and Great Britain. This paper presents a methodology for taxation resident of the Czech Republic, which achieved income from employment from the UK. This methodology is then applied to the example. Also part of the work is to define basic terms, the tax systems of both countries surveyed and procedures for calculating taxes in these countries.
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International Tax Optimization
Pavliska, Petr ; Havířová, Barbora (referee) ; Brychta, Karel (advisor)
This thesis deals with ICE - industrial services as The company must pay a withholding tax on their invoices received. Economic activity is undertaken in Germany. Company income from the supply of goods and services. Selected issue will be resolved by the formation of a permanent establishment or establishing a subsidiary in Germany. Developed solution provides the possibility of effective expansion into foreign markets. Results of the work allows the company to decide which option is best for her.
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International Taxation of Incomes of Czech Republic Tax Resident with Incomes from Canada
Mičulková, Hana ; Kotalová, Pavla (referee) ; Brychta, Karel (advisor)
The Master’s thesis focuses on taxation of employment income of the resident of the Czech Republic who also receives employment income from Canada. The thesis explains elementary principles and concepts related to income taxation of natural persons in the Czech Republic and Canada. The relevant articles of the Convention for the avoidance of double taxation are analysed. Based on the theoretical part of the thesis, a methodology for determination of a model taxpayer’s tax liability is designed with regard to available means of tax optimization.
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Permanent Establishment in the Czech Republic and its Taxation
Balabán, Jaroslav ; Irein, Vítězslav (referee) ; Brychta, Karel (advisor)
The Diploma Thesis „Permanent Establishment in the Czech Republic and its Taxation“ deals with the issue of double taxation focusing on the income of the permanent establishment. The first part of the thesis is focused on theoretical knowledge of an international double taxation, concept of agreements for the avoidance of double taxation, definition of the term „Permanent establishment“ and the taxation of permanent establishment. The second part is aimed at analysis Article 5 of Agreements for the avoidance of double taxation. The third part comprehends a model examples of the resident of Slovakia.
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Mezinárodné zdaňovanie fyzických osob
Štefunko, Rastislav
ŠTEFUNKO, R. International taxation of individuals. Bachelor thesis. Brno: Mendel University, 2019. The Bachelor thesis focuses on international taxation of individuals. It is concerned with the origin of double taxation, its forms and avoidance methods of double taxation. The situation is described from the perspective of nonresidents obtaining income from Czech republic and residents of Czech republic obtaining income from foreign countries. Domestic legislation and relevant international conventions are the subjects of analysis. It also focuses on relations with Slovakia in regards to international taxation and identifies the fundamental differences of personal income taxation between these two countries. Process of determining tax liability caused by obtaining various types of income and comparison of tax burden are presented by model examples.
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Withholding Tax Rate Elasticities of Foreign Direct Investment Outflows and Tax Revenue Consequences of Double Tax Treaties
Láznička, Jan ; Janský, Petr (advisor) ; Semerák, Vilém (referee)
This thesis provides a cross-country analysis of potential tax revenue losses due to the ways different countries tax over-border dividend and interest incomes of multinational enterprise. Withholding taxation of outgoing dividends and interest payments is regulated by domestic tax rules as well as bilateral double tax treaties. The signing of such a treaty might substantially reduce the tax rate levied by the source country on the outgoing passive income and thus decrease its tax revenue. We create a large panel dataset and estimate withholding tax rate elasticities of dividend and interest outflows for a large set of countries around the world. Subsequently, we use these elasticities to estimate potential tax revenue losses due to outgoing dividend and interest payments for the source countries in our dataset. The results show highly elastic dividend outflows, 2.3% - 2.58% decrease related to 1% increase in the applicable withholding tax. We also find substantial tax revenue losses due to dividend outflows for a number of source countries, the largest for Canada (1.35 - 3.19 billion USD) and the United States (2.27 - 2.94 billion USD). The investor country behind the largest part of potential losses shows up to be the Netherlands. JEL Classification F21, F23, H25, H26 Keywords double tax treaty;...
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