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Tax Implications of Companies Transformation
Galdunová, Natália ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
The diploma thesis deals with the companies’ transformation and the main focus is on the cross-border mergers and its tax implications. The theoretical part introduces the topic of companies’ transformation with focus on cross-border mergers and describes its legal, accounting and tax implications. The practical part contains of analysis of cross-border mergers made by Czech companies from 2008 to 2020. The goal of the analysis is to find out where to Czech companies make cross-border mergers most often. Then for the selected countries the tax systems and mainly the corporate income tax is described. Afterwards, with a model example, the most convenient country for cross-border merger from the tax and corporate income tax perspective is selected.
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Utilization of Tax Losses in CJEU Case Law
Hálová, Lenka ; Bělušová, Kristýna (referee) ; Brychta, Karel (advisor)
The bachelor's thesis deals with the admissibility of the tax loss in the context of the basic freedoms of the EU between the parent, subsidiary and grandchild companies. In the theoretical part, the basic terms are defined, which are necessary for the solved problem. In the analytical part, freedom of establishment is defined in more detail and selected judgments of the Court of Justice of the European Union are analyzed here. The proposal part contains a proposal for a methodical procedure for assessing the admissibility of losses for the parent company that were incurred by its subsidiaries or second-tier subsidiary companies.
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Tax Implications of Companies Transformation
Galdunová, Natália ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
The diploma thesis deals with the companies’ transformation and the main focus is on the cross-border mergers and its tax implications. The theoretical part introduces the topic of companies’ transformation with focus on cross-border mergers and describes its legal, accounting and tax implications. The practical part contains of analysis of cross-border mergers made by Czech companies from 2008 to 2020. The goal of the analysis is to find out where to Czech companies make cross-border mergers most often. Then for the selected countries the tax systems and mainly the corporate income tax is described. Afterwards, with a model example, the most convenient country for cross-border merger from the tax and corporate income tax perspective is selected.
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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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Common consolidated corporate tax base in the EU
Čondlová, Dagmar ; Kubátová, Květa (advisor) ; Schvábová, Andrea (referee)
The aim of my thesis is through comparative analysis find the differences between the newly proposed CCCTB directive and corporate income tax systems of France, Germany and Great Britain. The work is mainly focused on the comparison method of depreciation, access to inventory, the amount of corporate tax and transfer of tax losses. Although each system has its tax certain specifics, one would assume that the authors of the proposed directive let themselves be inspired by the strong states of the European Union. However, the final chapter of my thesis shows, that the majority of monitored items was not affected by these states.
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Accounting, legal and tax implications of cross-border mergers in EU
Skálová, Jana ; Mejzlík, Ladislav (advisor) ; Vomáčková, Hana (referee) ; Tumpach, Miloš (referee)
The purpose of my dissertation was to make an analysis of factors influencing the process of the carrying out of the cross-border merger of the Czech company with the company in the European Union. Solution procedure stems from a general definition of acquisitions and mergers, their historical development, reasons for the carrying out thereof, through the picture of these processes in international standards of financial reporting up to the regulation in the European Union. When analyzing the rules for cross-border mergers within the EU, I ascertained problematic places consisting in non-finalization of harmonization - in accounting context - of mergers, and in possibilities of a selection of a tax solution. Apart from the Czech legal regulation, I also analyzed the Slovak legal regulation since the last application part contains a practical example of merger of the Czech company and two Slovak companies carried out in 2009 and prepared on the basis of empirical data.
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The Optimalization of the Application of Deduction of the Tax Loss
Jančová, Lucie ; Slintáková, Barbora (advisor) ; Doležalová, Ivana (referee)
The aim of this bachelor thesis is to optimize the application of deduction of tax loss taking into account other tax deductions and tax reliefs. The first two parts are based primarily on Act No. 586/1992 Coll., on income taxes. They define the conditions for the application of the deduction of the tax loss, of the expenses (costs) from tax base by the realization of research and development programs, of the donation and of the tax reliefs. The third and last chapter applies these knowledges at the optimalization of the application of deduction of tax loss. The optimization is performed for two fictitious tax payers of the corporate income tax. The intention is to find the optimal combination of deductions and tax reliefs, when the taxpayer minimizes tax liability after taking into account the possibility of the additional tax assessment as a result of the tax audit. A procedure that reduces the disadvantage of inability to use the tax deduction against an additional increase in tax during the tax audit is set at the end of this thesis.
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Applicability and carry-over of tax losses, compared with the rules of the selected EU countries.
Fuksová, Barbara ; Říhová, Lucie (advisor) ; Vančurová, Alena (referee)
The aim of this bachelor thesis is to capture the development of legal regulations of a deduction of tax losses and its practical application and to compare the current legislation in the Czech Republic with the selected countries of the European Union. The thesis has character of qualitative research. The first three chapters contain descriptive research, which draws primarily from the legislative sources. The last part includes comparative analysis based on the information from Ernst &Young about the corporate taxation in the EU. The comparison shows that the Czech Republic with its terms does not significantly differ from the rest of the EU. Conditions for the deduction of the tax losses in individual countries are various but we can find their common features. Almost all member states have certain restrictive conditions, which are designed to prevent abuse of the deduction of the tax losses in the economically unjustified cases. Individual circumstances vary only in the form but their purpose is identical. The comparison also shows that there are elements that may limit the overuse of the deduction of the tax losses and stabilize the revenue of the public budgets. But the Czech Republic does not use these elements.
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