My diploma deals with the effective taxation from the corporate income. The main part of the thesis is aimed on general progress of the effective corporate tax as well as progress of the effective corporate tax in the Czech Republic. Effective corporate tax is a rate, which reflects the real taxation of corporates in particular states. The effective corporate tax arises from the statutory tax rate, which is adjusted by such items, which affect the final taxation. First part of the thesis deals with the options of set up of effective corporate income tax. The second part deals with the tax system in the Czech Republic. The analytic part is aimed on the progress of the effective tax rate. This part is attended by graphs, which show as well as compare the effective corporate income tax rate in particular states.

This thesis deals with corporate income tax in Austria. The aim of this thesis is to analyse the construction of corporate income tax in Austria into the details and identify good elements suitable for the application into the Czech juridical system. The first chapter is focused on GDP/tax revenues ration and its composition. Next chapter describes briefly theoretical attitudes to the corporate income tax. The main part of this thesis is contained in the chapter no. 3, which is focused on particular construction elements of this tax. There are also examples of taxation of two model corporations incorporated in Czech Republic and Austria in there. Next two chapters are focused on taxation in international context and on transactions with related parties. The last chapter identifies positive as well as negative elements of CIT in Austria and suggests recommendations for the Czech Republic. It recommends particularly reduction of interest expenses paid to the companies incorporated in tax heavens and the possibility of group taxation.

iv Abstract In this thesis on the effect of globalization on corporate income tax policies, we try to provide evidence that given the globalization-induced increased tax competition, countries are forced to lower their level of corporate income tax burden down to unsustainable levels or that they at least converge in their policies and levels of tax burden in order to attract international corporations through transparency. We find that no evidence to support such hypotheses is present in the OECD panel data of the last four decades with descriptive analysis, the general method of moments and the fixed effects estimation and we even find local evidence of an increase in the corporate income tax burden. Moreover, the OECD countries do not exhibit stronger convergence in their corporate income tax policies. Apart from the analysis of the general development of the corporate income tax burden, we find evidence that the level of tax burden is affected by the ratio of exports in the economy and correlated with the government indebtedness, outward FDI and the occurrence of the recent financial crisis. JEL Classification F23, F62, H25, H71, H87 Keywords globalization, corporate income tax, tax burden, tax competition, economic policy Author's e-mail vaclav.toman@gmail.com Supervisor's e-mail schneider@fsv.cuni.cz

This diploma thesis deals with the possibilities of transferring the cost of acquisition of depreciable tangible assets acquired by purchase or finance lease in the corporate income tax base, and analyzes the conditions of deductibility of depreciation and rent in the tax base. The diploma thesis identifies the factors affecting the amount of the tax base for both variants of the acquisition of depreciable tangible assets and the elements of the tax optimization.

A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, in partial fulfilment of the requirements for the degree of Master of Commerce (specializing in Taxation) Johannesburg 2015 / Due to the vast number of groups of companies having many subsidiaries that are no longer viable from an economic perspective or that no longer gain the tax benefit that they were first created to achieve, there are many group restructurings occurring. These restructurings are to potentially simplify the group structure as well as achieve the maximum tax benefit. This research report will analyse how groups may be restructured in line with the provisions of the Income Tax Act (‘the Act’) as it stands currently by looking back at how restructurings were dealt with in the past and how that has now evolved. The research discusses the corporate rollover relief provisions that may be applied in order to simplify the restructuring process which is commonly used in today’s practice. The research suggests that there are many different ways to restructure a group in order to gain the maximum amount of benefit from a tax perspective. Key Words: branch, capital gains tax (CGT), corporate income tax, corporate rollover relief, deregistration, foreign tax resident, general anti-avoidance rules (GAAR), liquidation, partnership, restructure, value-added tax.

The thesis analyses and assesses tax systems in the Czech Republic, Austria, Estonia, Latvia and Ukraine. Each structural components of corporate income tax and also taxation of profit shares paid to partners are compared. The comparison of taxation concepts are drawed mainly from the national perspective but the cross-border aspects are described as well. Based on all findings the conclusions about advantages and disadvantages of the tax systems are set.

新企業所得稅法實施後，內外資企業所得稅法被統一，不一致的情形被消弭，稅收優惠的政策也從對外資企業的普遍優惠制轉變成以產業為導向。凡此種種改變，皆對中國大陸上市企業之有效稅率產生影響。本文以2003年-2010年中國大陸上市企業的財務資料做實證研究。 本文主要研究的課題有三：一、探討新企業所得稅法實施前後稅前扣除規定對有效稅率的影響；二、新企業所得稅法中規定的反資本弱化條款對企業有效稅率是否有影響？；三、內外資企業所得稅兩稅合一之後，各地區是否仍有顯著的稅境差異？ 第一個課題用兩個變數來捕捉，一個是薪資費用，一個是營運費用。薪資費用在內外資企業所得稅兩稅合一前與有效稅率為負相關。本文推論該情形因為高階管理人員的薪資沒有正常列報，而可能的原因有三：一、租稅規劃原因，二、避免薪酬過高引起社會各界關注，故分配在各個關係企業，三、國家對國有企業的高階管理人薪資有限制。 營運費用在內外資企業所得稅兩稅合一前與有效稅率為正相關，與假說預計情況相同。這部分可用財稅差異的觀點來解釋。而內外資企業所得稅兩稅合一之後，應納稅所得額的計算規則更為公平合理，故營運費用對有效稅率的影響為負相關。第二個課題是討論資本弱化條款的問題。內外資企業所得稅兩稅合一之後，該變數之係數呈現顯著正相關，代表中國大陸在內外資企業所得稅兩稅合一之後，反避稅措施的實施已然有些成效。 第三個課題是稅境差異的問題。本文地區性虛擬變數的設置以西部地區為對照組。內外資企業所得稅兩稅合一之前，較明顯享受稅收優惠政策的地區是西部地區與經濟特區，故東部地區與中部地區的係數顯著為正，而經濟地區呈現不顯著的狀態。內外資企業所得稅兩稅合一之後，地區別的稅收優惠政策只剩下西部地區中的鼓勵類產業才能享受，而實證結果也明確顯示中國大陸政府預期的結果。 / After new enterprise income tax law enacted , income tax law applicable to both domestic and foreign-owned enterprise are unified,the difference between those income tax law are gone. The new law scraps the original emphasis on regional incentives in favor of industry-oriented incentives supplemented by regional ones . All of these changes affect corporate effective tax rates of China Listed companies . This study used the sample of china listed companies spanning from 2003-2010. This study have three main topics : First, to discuss how the pre-tax deduction rules affect corporate effective tax rates before and after implementation of the new law. Second, does the anti-thin capitalization rule in the new law have some effect to corporate effective tax rates? Third, after implementation of the new law,are there still big difference between regions? This study used two variables to examine first topic-salary expense and operating expense. Salary expense had a negative correlation with corporate effective tax rates before implementation of the new law. I consider it came from salary information disclosure of senior executives which could be explained in three ways. First, tax planning purpose. Second, in case of drawing attention from publics, part of salary were paid by affiliated companys. Third,the country imposed caps on senior executive pay in state-owned enterprises. Operating expense had a positive relation with corporate effective tax rates before implementation of the new law which is the same as hypothesis. It could be explained in terms of book-tax differences. After implementation of the new law, rules for computation taxable income are more fair and reasonable. As a result, operating expense has a negative relation with corporate effective tax rates. The second topic discuss about anti-thin capitalization rule.After implementation of the new law, the variable standing for anti-thin capitalization rule is significantly positively correlated with corporate effective tax rates.It represents that, after implementation of the new law, China authorities make progress in anti-tax avoidance. The third topic is about tax burden between regions. This study used western region as a control group. Before implementation of the new law, preferential tax policies were subject to western region and Special Economic Zones. For this reason, the region dummy variables—central China and east China were significantly positively correlated with corporate effective tax rates, but the coefficient of western region dummy variable did not reach statistical significance. After implemention of the new law, preferential tax policies is subject only to domestic enterprises belonging to the category encouraged by the State in western region. The empirical results conform to the anticipation of China authorities.

In this paper, we test one of the fundamental assumptions in the tax competition literature, namely, that a country's taxable income depends on the tax policies pursued in the domestic and in neighbouring countries. Based on a panel of annual data of 14 western European countries spanning the period 1982 to 2004, we show that the common trend in falling corporate income tax (CIT) rates can in part be explained by the existence of fiscal externalities in the form of international resource flows. Our results confirm the presumption put forward in recent empirical tax reaction function studies, that interdependent tax setting behaviour is evidence of tax competition. However, taxable corporate income is shown to react inelastically to domestic and to foreign tax rates. Thus, the observed rise in CIT revenues in Europe between 1982 and 2004 cannot be explained by the trend in falling CIT rates. Moreover, we find that large countries' tax bases are more responsive to neighbouring countries' tax policies, which is in contrast to the classic asymmetric tax competition literature. (author´s abstract) / Series: Discussion Papers SFB International Tax Coordination

In this paper, we test one of the fundamental assumptions in the tax competition literature, namely, that a country's taxable income depends on the tax policies pursued in the domestic and in neighbouring countries. Based on a panel of annual data of 14 western European countries spanning the period 1982 to 2004, we show that the common trend in falling corporate income tax (CIT) rates can in part be explained by the existence of fiscal externalities in the form of international resource flows. Our results confirm the presumption put forward in recent empirical tax reaction function studies, that interdependent tax setting behaviour is evidence of tax competition. However, taxable corporate income is shown to react inelastically to domestic and to foreign tax rates. Thus, the observed rise in CIT revenues in Europe between 1982 and 2004 cannot be explained by the trend in falling CIT rates. Moreover, we find that large countries' tax bases are more responsive to neighbouring countries' tax policies, which is in contrast to the classic asymmetric tax competition literature. (author's abstract) / Series: Department of Economics Working Paper Series

iv Abstract The thesis focuses on base erosion and profit shifting (BEPS) and resulting corporate income tax gains or losses. I first estimated profit shifting semi-elasticity using database of firm-level financial data. Subsequently I used these estimates to calculate corporate income tax gains or losses for individual countries. I estimate several models to see how much the semi-elasticity depends on specification and what affects it. The evidence suggests that companies do shift profits to countries with lower tax rate. The estimated overall profit shifting semi-elasticity ranges from 1.524 to 3.695 for different specifications of the benchmark model. Semi-elasticity of individual countries increases with financial secrecy score. Using statutory tax rate yields stronger results than using country-level effective tax rates calculated from the financial data. The estimated effect on government revenue ranges from 12% loss to 23% gain of corporate income tax revenues. In the sample of 53 countries with sufficient number of observations this translates to overall loss 48 billion US dollars. JEL Classification F23, F68, G38, H25, H26, H87 Keywords base erosion, profit shifting, corporate income tax, financial secrecy Author's e-mail michal.petrous@gmail.com Supervisor's e-mail jansky@fsv.cuni.cz