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International double taxation
Řezníčková, Markéta ; Kotáb, Petr (advisor) ; Sejkora, Tomáš (referee)
This diploma thesis deals with some questions of the international double taxation, particularly with the basic terminology and principles of the international taxation, bilateral double taxation treaties and new tools of legal regulation of the international double taxation such as BEPS, MLI, a package of European directions called Anti-BEPS and its implementation into the Czech law. The aim of this thesis is to identify, describe and analyse sectional questions in respect to long-term and current evolution. In the introduction I briefly introduce the topic. Afterwards the thesis is divided into four chapters that are linked to each other. The first chapter presents to the reader basic terminology and explains basic principles of this field independently and in relation to current legal regulation. Further I describe the types of double taxation and other institutes related to the international double taxation such as international double non-taxation. The second chapter deals with means of elimination of the international double taxation. Two basic methods are described and some of them are represented by basic examples. There are also described means of elimination of the international double taxation that can only be used in tax treaties (not in the national law). The last subchapter describes...
International Tax Planning and Optimisation
Večeřová, Tereza ; Svirák, Pavel (referee) ; Kopřiva, Jan (advisor)
This diploma thesis deals with the issue of international tax planning and tax optimization. Based on the acquired theoretical knowledge, the key factors that are identified should be relevant for business entities within the framework of international tax planning. The following methods which are mentioned can be used in international tax optimization. The work concludes with a proposal for the implementation of international tax planning and corporate income tax optimization on a model example.
Taxation of income of business companies and their members (comparison of legal regulation in the Czech Republic and Slovakia)
Důjková, Zuzana ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
75 Resumé v anglickém jazyce a klíčová slova Taxation of income of business companies and their members (comparison of legal regulation in the Czech Republic and the Slovak Republic) My diploma thesis called "Taxation of income of business companies and their members (comparison of legal regulation in the Czech Republic and the Slovak Republic)" focuses mainly on the differences between legal regulation of system of income taxation in the Czech and Slovak Republic. Whereas a business company could be considered solely a legal entity, a member of a business company could be an individual as well. Therefore both areas of income taxation - personal and corporate income tax - are included into the comparison in this diploma thesis. After the introduction the thesis is divided into seven chapters. The first one describes the most important characteristics of particular business companies as they are stipulated in Act No. 513/1991 Coll., Commercial Code, as amended. I have introduced the key features of the most known legal forms of business companies - general partnership, limited partnership, limited liability company and joint stock company. The legal regulation of these types of business companies is similar in the Czech and Slovak Republic. The second chapter deals with legal regulation of both personal and...
The institution of a permanent establishment in tax law
Vaněk, Marek ; Kotáb, Petr (advisor) ; Vybíral, Roman (referee)
1 Abstract Title: The concept of the permanent establishment in the tax law Author: Marek Vaněk Supervisor: JUDr. Petr Kotáb, Ph.D. This thesis analyses the law concept of the permanent establishment, mainly the legislation contained in the OECD Model Tax Convention and in the Income Tax Act. The first part of the thesis analyses the types of permanent establishment (fixed, building and construction sites, service-based, agent-based and permanent establishment of the shareholders of partnerships and limited partnerships), separately according the OECD Model Tax Convention and according to the Income Tax Act. The thesis also analyses subsequent sources of law. The thesis includes a detailed analysis of conditions which are necessary for the existence of the permanent establishment, inclusive examples, including information of the Ministry of finance and the General Financial Directorate that have impact on the permanent establishment treatment. Furthermore, the thesis deals with the determination of the tax residency of persons and legal bodies which is a significant factor for the application of bilateral double taxation treaties (mainly with the circumstances of the existence of the permanent establishment), including the issues connected with proving of the tax residency of the tax transparent entities....
Model agreements on double taxation avoidance in the practice of the Czech Republic
Taschner, Lukáš ; Kotáb, Petr (advisor) ; Novotný, Petr (referee)
This thesis deals with international taxation, which is becoming an increasingly important issue due to the globalization of world economy in recent decades. International taxation is a broad topic including a variety of problems concerning it. Among the most important recognized phenomena are International double taxation and tax evasion. The conclusion of bilateral tax treaties seems to be the most efficient instrument for their solutions so far. Model Tax Conventions have been prepared by international organizations for the purposes of coordination of structure, wording and interpretation of numerous bilateral agreements. The OECD Model Treaty and the UN Model Treaty are widespread worldwide, being legally non- binding models for negotiations of bilateral agreements. In addition to those, the proposal of a new multilateral European Union Treaty has appeared. It should be signed by all members of the European Union, and it would replace all bilateral agreements concluded between the EU member states. Within the global community of other states and nations, the Czech Republic has an open and liberal economy. Therefore, it is necessary for the Czech Republic to have all international tax issues ensured with each economic partner. Over the past twenty years, the Czech Republic has concluded 67 out...
International taxation of limited companies - a comparison between Czech Republic and Russia
Aharonyan, Elen ; Novotný, Petr (advisor) ; Vondráčková, Pavlína (referee)
The object of this thesis is international taxation of companies. It focuses on the comparison between the Czech Republic and the Russian Federation. The first chapter focuses on the tax systems of both countries, dealing with what kind of taxes exist and what is taxed, and all this on a general level, which is crucial for further comparison that is made in final chapters of the thesis. According to the topic, the thesis gives a description and definition of the companies, what kind of companies exists in both countries and what is related legislation. It is followed by a chapter on international taxation, describing international taxation issues on a general level and explaining main definitions it deals with, without which this issue cannot be understood. It discusses how countries avoid of double taxation on an international level, and what tools exist for it. Afterwards it explains international taxation of companies and specifically provides the analysis of The double taxation treaty between the Czech Republic and Russia, also by showing examples for better understanding of this issue.
Misalignment of Profits and Economic Activity by Multinational Enterprises
Cimpová, Dominika ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
This thesis analyses the profit shifting behaviour of U.S. multinational companies using panel data set over the period 1983 - 2015. The main objective of the thesis is to com- pute the extent of misalignment between reported profit and real economic activity and consequential revenue losses caused by profit shifting and to estimate the effect of tax rates on profit shifting behaviour. Using country-level aggregated data published by the Bureau of Economic Analysis I found a substantially increasing trend in the misaligned profit reaching 540 bn US$ in 2015 which is accompanied with tax revenue losses 190 bn US$ in missing profit countries. Majority of the misaligned profit is reported in a small number of jurisdictions with near zero tax rates such as Netherlands, Ireland and Luxem- bourg. Additionally, I found a significant negative effect of tax rate on misalignment in the recent years, however, only negligible effect at the beginning of the examined period. Results suggest that 1% increase in the statutory tax rate can cause 2.5% growth in the magnitude of misalignment. My findings are consistent with the existing literature. Ac- cording to the analysis it can be concluded that despite numerous attempts for prevention of profit shifting, it is becoming more serious problem than ever before.
Institute of Permanent Establishment in Tax Law
Ngo, The Vinh ; Kotáb, Petr (advisor) ; Vybíral, Roman (referee)
This master's thesis conducts the legal analysis of the concept of a permanent establishment and its individual characteristics. The first chapter of this master's thesis provides a brief introduction to the issue of international taxation and introduces the basic ideas behind the concept of a permanent establishment. The theoretical introduction is followed by a historical excursion into the development of this concept from its beginnings to its current modern form in the twenty-first century. The second chapter deals with the very essence and construction of the concept of a permanent establishment which is enshrined in bilateral tax agreements and the OECD and the UN Model Tax Conventions. Hence, the introduction of this chapter focuses on explanation of the essence and binding nature of these international sources of law. Subsequently, a detailed analysis of the concept of a permanent establishment and its components is conducted. At the end of this chapter a comparative analysis of the definitions of a permanent establishment in the OECD and the UN Model Tax Conventions is conducted. The third chapter briefly describes the relationship between various definitions of a permanent establishment which may be found in international and national legal instruments. The following sections of this...
How Much in Taxes Do Multinational Enterprises Pay?
Boukal, Tomáš ; Janský, Petr (advisor) ; Palanská, Tereza (referee)
Taxation of multinational enterprises accounts for a significant portion of government revenues. These revenues are however negatively affected by the tax behavior of many multinational groups which shift significant part of their profits to tax haven countries. The prevailing body of the literature on this topic has focused on the quantification of shifted profits and the resulting tax losses. Thus, the question of how much multinational enterprises do pay on taxes has remained unanswered. This has changed with the recent publications of Bolwijn et al. (2018) and Tørsløv et al. (2018). The aim of this thesis is to discuss their methodologies, apply them and present the amount of taxes paid by foreign affiliates of multinationals in individual countries. We express the results as a portion of GDP to enable cross-country comparison and put them in contrast to the estimates of tax losses from profit shifting. Keywords multinational enterprise, corporate income tax, international taxation, government revenue, tax avoidance
Sestavení transakčního a daňového modelu mezinárodní sportovní soutěže
Hrubá, Iveta
The diploma thesis deals with the creation of transaction and tax model for an international yachting competition organized in Croatia. As different nations have different regulations and taxes on monetary transactions, this thesis aims to streamline this process. In thesis are defined and classified all taxable transactions made by various entities involved, with respect to the regulations of each state involved, as well as international regulations. After identifying the specifics of each transaction, transaction and tax model adhering to all relevant regulations is created. The thesis also contains a draft of the economic and contractual setting of the competition.

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