This diploma thesis is focused on a critical comparison of the tax burden on real estate in the Czech Republic and in selected countries of the European Union. At first, comparison will be implemented on the general level, after that a practical calculation for the most popular type of housing will be realized. This thesis provides a comprehensive view of the tax on real estate and business transfer. A comparison of taxes related with real estate in the countries of the European Union will be used for a prediction of the tax burden on real estate in the Czech Republic for the following years.

This diploma thesis focuses on the analysis of the effectiveness of transfer taxes in the period 2006 to 2010 in the Czech Republic. The first part of this thesis describes the historical development and the basic characteristics of transfer taxes in the Czech Republic and analyzes in details the current legislation. The second part deals with the analysis of the effectiveness of transfer taxes, i.e. measurement of the administrative costs of taxation and their subsequent comparison with revenues. The measurement of the administrative costs is used by the method called WTE staff. On the base of the measurement is done the conclusion about the administrative costs of taxation and about efficiency of transfer taxes in the tax system of the Czech Republic. The third part discusses on plans for future development in this area of transfer taxes in the Czech Republic.

Diploma thesis is focused on the comparison of the tax burden on residential property owner in the Czech Republic and in selected European countries. The content of this thesis is a comprehensive review of taxes relating to real estate in our country, their detailed analysis and subsequent comparison with the situation of selected countries. The possible future development of property taxation in the Czech Republic is predicted in conclusion.

The thesis deals with tax liabilities of an owner of real estate. The theoretical part describes tax acts in 2010 which are used in the thesis. I focused on selection of the parts of the acts which refer to real estate so that the public can easily understand and use them. The practical part includes taxation of specific cases with commentary and reasoning of individual steps arising during purchase, usage and transfer of real estate. The specific cases are modelled for a natural person taxpayer not being an entrepreneur and a natural person taxpayer being an entrepreneur.

米国における富の移転課税制度とその課税根拠論について検討し，その検討結果を踏まえて，今後のわが国における富の移転課税制度のあり方について考察した。本研究の主な検討課題は，(1)課税制度の歴史的展開，(2)実体法としての連邦遺産税，贈与税および世代跳躍移転税の検討，(3)課税根拠論，である。本研究により，米国における富の移転課税は，税法独自の定義と概念に基づいて法が構築されていることが明らかとなった。 / The wealth transfer taxation in the United States of America was studied to clarify the legal characteristics in the tax system. The study is composed of a history of federal estate, gift, and generation-skipping taxes, current legal aspects of those taxations, and the rationale for the taxations. The characteristic of the legal aspects in the wealth transfer taxation in the nation is to tax a right and competence for a wealth. The theory of the taxation would be important issues in Japan. / 博士(法学) / Doctor of Laws / 同志社大学 / Doshisha University