My thesis is concentrated on double taxation issues in European Union countries. Target is to describe various systems of dividends taxation in different EU countries and compare them with system that Czech Republic uses, to evaluate how effectively are double taxation eliminated based on the double taxation treaties. Efficiency of double taxation avoidance is measured by calculation of value "overtaxation". In the theoretical part of the thesis are the term double taxation defined and the reasons of their source and methods of their elimination are mentioned. Practical part is dedicated to comparison how the different countries are handling with dividends taxation in their domestic legislation and furthermore the ways of dividends taxation in their double taxation treaties are explained. In the conclusion of the thesis are the topics for the practice given, and the actual tax system of Czech Republic development is described.

Magister Philosophiae - MPhil / Over the years, the world economy has experienced growth in foreign direct investments (FDI), with the role of developing countries becoming more evident as both recipients and investors alike. The proliferation of international investment has also led to more bilateral investment treaties (BITs) with their complex and often duplicated rules. The increase in BITs of this complex nature has thus resuscitated a less publicly debated course, although recently discussed within the United Nations Conference for Trade and Development (UNCTAD), is there need for multilateral agreement on investment (MAI), hosted within the multilateral institution(s)? Since the late 1990s, the discussion as to whether international investments require the MAI has been characterised by diverging interests of developed and developing countries, with neither willing to concede. Even in the immediate post-War II period, this standoff between developed and developing countries has dominated a discourse on whether there is a need for an international agreement on international investment. Yet developing countries, or African countries classified as least developing, continue to be left out of MAI discussions. For example, the Organisation for Economic Cooperation and Development (OECD) 1990's proposed plurilateral agreement excluded African countries.

The thesis is focused on holding companies legislation in the Czech Republic and related issue of tax optimization in the international business environment. First aim of this thesis is to map control and influence relations and therefrom arising legal obligations within Tescoma Group. Second aim is to explore Tescoma Group from the point of view of tax optimization and to compare advantages and disadvantages of alternative structures of the group.

Thesis deals with tax haven topic taking part in the gaming industry, international tax planning and tax losses related. In the theoretical section, definitions and anti-tax evasion strategies are introduced; and overview of particular countries solution with its features is outlined. The application section quantifies effect of these particular features on increase/decrease of tax residents count using statistical methods. Findings consist also of recommendations for tax code improvement and gaming law enhancements for Ministry of Finance in Czech Republic.

Taxation of permanent establishments is one of the most complicated areas within international tax law. The system of permanent establishment is based not only on the national legislations of relevant states, but also (mainly) on the international double taxation treaties. This diploma thesis analyses those issues in the taxation of permanent establishments, which are the most up-to-date or can be considered as the key questions of the whole concept and therefore can be significant for the future development of the permanent establishments. However the technically perfect system of permanent establishments should come hand in hand with the practical feasibility and overall efficiency. This assumption is nowadays challenged by several trends like the growing popularity of offshore tax heavens or the development of information technologies, which complicate the determination of (fixed) place of business through which the business of an enterprise is wholy or partly carried on. The technical analyses in this thesis are, therefore, supplemented by the objective evaluations from the perspective of valid legislation, possible approaches of the tax authorities, as well as of the enterprise considerations and also the global international taxation picture. This involves also the aspects of tax policies at the level of sovereign states, especially the Czech Republic.