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Tax Havens and their Utilization
Malý, Zdeněk ; Dubový, Roman (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis describes the topic of tax havens and their usage. Further it describes issues of international tax planning. The thesis is divided into three parts. The first one, theoretical, explains basic concepts of this issue. Analytical part follows with description of present state of taxation in selected countries. The last section of this thesis shows some uses of tax havens and whether or not it offers tax advantages.
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General Anti-Abuse Rule
Vraštil, Martin ; Sejkora, Tomáš (advisor) ; Kotáb, Petr (referee)
GeneralAnti-Abuse Rule Abstract This thesis first deals in general terms with the basic classification of taxpayers' strategies for reducing their taxes based on compliance of these strategies with the law. It then focuses on the legislative responses having the form of General Anti-Avoidance Rule of the supranational and the state entities which are most relevant in relation to Czech taxpayers. These are the General Anti-Avoidance Rules contained in the sources of European Union law and the General Anti-Avoidance Rules contained in the legal order of the Czech Republic. The aim of this thesis is to determine the content of the General Anti-Avoidance Rule and thus to answer the question of what this measure truly is. This aim is achieved by analysing relevant sources of law and secondary literature, by describing the content of the European and Czech General Anti-Avoidance Rules and by comparing them with each other. In the chapter which is dealing with General Anti-Avoidance Rules in the European Union, this thesis first focuses on the historical development of various forms of General Anti-Avoidance Rules in European Union law. In this chapter the author then describes the particular components of a European General Anti-Avoidance Rules, which precisely represent the procedural steps a tax authority...
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Taxing the digital sector
Ondřej, Lukáš
This thesis is about the taxation of the digital sector of the economy. Currently, this issue is being discussed because of the fast development of these services, where the current rules for taxation of goods and services are still dependent on the physical presence of entities at the point of sale and thus unusable. The work is focused on existing systems and proposals on how to tax this sector in the EU, problematics in international tax planning and aggressive planning to reduce the tax base. The aim of the thesis is to compare available proposals and established regimes in the EU and to draw a proposal for taxation of digital services for the Czech Republic. The main method of this thesis is to analyze the obtained data for the subsequent comparison of indicators and benefits for the Czech Republic. The thesis offers an insight into the digital sector, countermeasures by individual states by application of unilateral measures and the EU measures and effort to come up with a common tax regime. The main benefit of the thesis is the proposal for taxation of the digital sector in the Czech Republic and the estimate of possible revenues. The Czech Republic has started to address this issue in early 2019, but it is still uncertain how or when this taxation will occur.
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Analysis of specific instruments applied in the financial management of TNC with a focus on transfer pricing
Baluchová, Daniela ; Taušer, Josef (advisor) ; Sato, Alexej (referee) ; Baláž, Peter (referee)
Transfer pricing plays a crucial role in the financial management of TNC as it significantly influences revenues and costs allocation among affiliates of TNC that are located in countries with different tax regimes, interest rates, political situation and economic environment. Recently, transfer pricing is scrutinized in respect of tax minimisation strategies adopted by TNC which raises various conflicts of interest with tax authorities in some countries of their presence. The main objective of the dissertation thesis is to provide a comprehensive empirical study on international transfer pricing in the Czech Republic from the perspectives of both taxpayer and the tax authority. With regard to the complexity of transfer pricing, manufacturing afiliates of TNC located in the Czech Republic were selected to be examined in more detail. The thesis is structured into five chapters. The first chapter defines theoretical framework based on which the analytical part of the thesis is elaborated. The strategies applied by TNC in setting transfer prices are strongly affected by the transfer pricing regulation and interpretative experience of the particular countries in which they operate. In this context, the Czech transfer pricing legislation as well as selected case law is analyzed in the second chapter. Given the complexity of the issue of transfer pricing, the third chapter deals with selected aspects that are considered critical when setting transfer prices. The fourth chapter presents key findings regarding transfer pricing strategies applied by TNC located in the Czech Republic to transfer pricing issues. The fifth chapter summarizes the approach of the Czech tax authorities to the transfer pricing audits and at the same time evaluates related risks borne for taxpayers in this respect. The thesis reveals that manufacturing afiliates of TNC located in the Czech Republic generally prefer non market (cost based) transfer pricing methods when setting transfer prices, whereby there are several factors influencing their decision making, out of which internal economic conditions and foreign exchange risk management are deemed the most important factors, while tax optimisation as well as restrictions on profit repatriation are considered relatively less important factors. The study further indicates certain inconsistency between declared functional and risk profiles and decision making competences. In this connection, it was found out that the Czech afiliates in which the foreign parent company is involved in transfer pricing set-up incur tax losses. In response to the increasing importance of transfer pricing and international initiative Action Plan BEPS (Base Erosion and Profit Shifting) it can be stated that the approach of the Czech tax authorities has become more intensified and sophisticated. The Czech tax authorities challenge declared and actual functional and risk profile of taxpayers as well as economic substance of realized intercompany transactions. Furthermore, number of transfer pricing audits has increased and become targeted on risky taxpayers such as companies granting investment incentives or incurring tax losses etc. As a result, additional tax assessment due to incorrect transfer pricing significantly increases over recent years.
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Tax Havens and their Utilization
Malý, Zdeněk ; Dubový, Roman (referee) ; Kopřiva, Jan (advisor)
This bachelor thesis describes the topic of tax havens and their usage. Further it describes issues of international tax planning. The thesis is divided into three parts. The first one, theoretical, explains basic concepts of this issue. Analytical part follows with description of present state of taxation in selected countries. The last section of this thesis shows some uses of tax havens and whether or not it offers tax advantages.
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