The Master's thesis is concerned with optimizing the tax costs and tax expenditures of sole proprietor or legal entity businesses. Main objective of this thesis is to introduce the tax cost and tax expenditures, which can be optimized, as widely as possible and to analyze the most important methods of tax optimalization relevant to most business entities. To achieve this objective the thesis is divided into theoretical and practical part. The theoretical part is focused on a definition of tax, tax system of the Czech republic including more detailed descriptions of income taxes and value added tax, effects of taxation on an enterprise and reasons for tax optimalization related to it and last but not least the thin line between tax avoidance and tax evasion. The practical part introduces through verbal description and practical examples the most important methods of tax optimalization relevant to most business entities, i.e. income tax and value added tax. Finally the thesis deals with international tax planning and methods of cash flow management connected with tax administration.

This thesis is focusing on methods of tax optimization of international companies. These international concerns are endeavoring tax minimization. The disparity of the tax systems gives to these companies a possibility of profit and tax base shifting. At first this thesis compares the differences of tax optimization, aggressive tax planning and tax evasion. Among the areas of the optimization methods, which are described in this thesis, belongs tax residention, dividends, royalty payments, transfer pricing and the companies conversions. Because of the aggressive tax optimization are the public budgets shortened by million crowns. As a reaction many of guidelines and plans of international organizations has been written to worsen the possibilities of tax planning. The impacts on public budgets are shown and counted on the model example of fictive international company.

The thesis is focused on international double taxation and its implications for international business activity. At first, it focuses on double taxation definition, the reasons of its occurrence and its impacts. The next part deals with bilateral double taxation treaties and their principles, including a comparison of Model conventions developed by the OECD and the UN. The last chapter focuses on the areas of transnational corporations activity that are most impacted by tax matters, such as the form of their presence in the foreign market, transfer pricing and international labour hire. The basic principles of international tax planning are explained as well.

Submitted by Nadir Basilio (nadirsb@uninove.br) on 2016-05-13T20:27:50Z No. of bitstreams: 1 Yuri Lanes.pdf: 469055 bytes, checksum: 1cb8a7f1385b3d6aa32466135a655b2d (MD5) / Made available in DSpace on 2016-05-13T20:27:50Z (GMT). No. of bitstreams: 1 Yuri Lanes.pdf: 469055 bytes, checksum: 1cb8a7f1385b3d6aa32466135a655b2d (MD5) Previous issue date: 2015-12-17 / This dissertation discourses the issue of effective and functionalization of fundamental rights and guarantees by means of taxation. It is a work that seeks to analyze countless issues relating to the rights o valor moral de uma of equality, freedom and solidarity ant, through an analysis of corporate ethical behavior and hegemonic globalization’s impact in the State, it seeks to find, from a theoretical perspective, models and arguments for the effectiveness and functionalization of basic rights of the legal pact and policies of counterhegemonic globalization for taxation (in the view of the strategic tax planning). The main objective of this work is to present the idea of fundamental rights by checking their hypotheses and normative statements, in addition to examining the possibilities for for realization of these rights through taxation for the construction of more cohesive and sustainable society. The adherence work to the master’s research line is realized while looking up foundations and proposals for State intervention in order to induce marked corporate behavior from the perspective of fundamental rights and guarantees by the strategic tax planning. Based on the deductive method to provide the analysis and considerations point about society, the legal system, the rights and guarantees, ethics and taxation. / O presente trabalho aborda a questão da efetivação e funcionalização dos direitos e garantias fundamentais pela via da tributação. Trata-se de um trabalho que busca analisar questões atinentes aos direitos de igualdade, liberdade e solidariedade e, passando por uma análise do comportamento ético empresarial e dos impactos da globalização hegemônica nos Estados, busca-se encontrar, de uma perspectiva teórica, modelos e argumentos para a efetivação e funcionalização de direitos basilares do pacto normativo e de politicas de globalização contra-hegemônica pela tributação (na ótica do planejamento estratégico tributário). O objetivo principal do presente trabalho é apresentar a ideia dos direitos fundamentais, verificando suas hipóteses e previsões normativas, além de examinar as possibilidades de efetivação desses direitos através da tributação para a construção da sociedade mais solidária e sustentável. A aderência do trabalho à linha de pesquisa do mestrado se concretiza ao passo que se busca fundamentos e proposições para uma intervenção do Estado com a finalidade de induzir comportamentos empresariais balizados na perspectiva dos direitos e garantias fundamentais pelo planejamento estratégico tributário. Para tanto, utiliza-se do método dedutivo para proceder uma pesquisa com material bibliográfico com o objetivo de se encontrar suporte para proporcionar a análise e considerações a respeito da sociedade, do ordenamento jurídico, dos direitos e garantias fundamentais, da ética e da tributação.

The Master's thesis is focused on tax optimalization through tax havens. The Master's thesis is divided into six parts. The first part generally outlines the problems of international tax optimalization. The next one defines concepts related to tax havens, use of tax havens and the fight against tax evasion. The third chapter concentrates on direct foreign investments, which are connected with holding companies. Information from this chapter is used in the following chapters. The practical part consists of two and shows the costs for establishment of a model subsidiary and the tax costs of the company for the first year of its running in chosen tax havens. These costs together with other information about chosen tax havens are analysed. Subsequently, a suitable location for the company in one of these destinations is suggested.

The diploma thesis focused on international tax planning and tax optimization. The diploma thesis specifies what is an international tax planning and underlines its importance in these days. On theoretical knowlege the diploma thesis summarizes key factors that should entrepreneurs in international tax planning and optimization to take into account. End of the thesis presents proposal the progress of the process of international tax planning and also on the particular case.

The diploma thesis is focused on issues of the tax havens and their use in international tax optimization. The paper processed knowledge of tax planning and the need to optimize the tax burden of the tax payer, with the help of offshore landscapes. In the first one, there is the theoretical basis and the issue of tax havens and tax planning, which in practical part is followed by ananalysis of selected countries and the design of optimal structure of taxation.

The master´s thesis is focused on the characteristic of tax havens and their possible utilization. On the basis of the literature in the theoretical part there are described the basic assumptions of international tax planning, agreements for the avoidance of double taxation and tax havens. Analytical part describes selected tax havens. The practical part of the thesis deals with the possibilities of tax optimalization through the utilization of tax havens.

The master thesis deals with the issue of taxation in selected tax havens. The thesis first outlines the characteristics of particular tax havens and the basic concepts related to this issue. Afterwards, selected tax havens, their tax system and companies that can be cre-ated there are analysed. Subsequently, on a model example are outlined advantages of taxation in selected tax haven.

Master thesis deals with tax havens and their utilization. In the teoretical part are defined fundaments of the tax havens and their utilization. Next part of thesis is analysis of tax havens in the Middle East. In this part focus is on coutries like Bahrain, Qatar or United Arab Emirates. Based of founded facts are concluded recommendations for concrete company with aim to reduce taxation.