The main objective of the Thesis is to specify the crucial aspects of professional football players income taxation in the Czech Republic. These incomes are taxed according to the section 7 Income Tax Law. The Thesis is also aimed at taxation of non-resident football players. The international taxation is explained on the Model Tax Convention on Income and on Capital and on the Czech Income Tax Law. In the second part of this Thesis the fictious tax duty of selected football palyers is layed down. key words: professional football player, income tax, income tax

This thesis analyzes the concept of corporate residence, with particular reference to the law in the UK and Canada. It explores why corporate residence is relevant in tax policy, how corporate residence is understood in law, and how revenue authorities respond to the use and alleged 'abuse' of residence rules. Part I argues that the residence of taxpayers generally (individual or corporate) remains a relevant factor in international tax design, that taxation of corporations on the basis of residence has some justification, but that there is a disjunction between meaningful residence-based taxation and current definitions of corporate residence in domestic law and tax treaties. The formulations of residence based on incorporation, central management and control, and place of effective management, particularly as applied to multinational enterprises, are considered and are found to be deficient. Part II critically analyzes the major policy responses of the UK and Canadian governments to the exploitation of corporate residence. It argues that key legislative and administrative responses to international tax avoidance activities, for both outbound and inbound investment, are purportedly based on the acceptance of formal corporate residence yet undermine that concept in an effort to impose tax or refuse treaty relief based on where economic interests actually exist. The responses considered are the application of controlled foreign companies legislation to offshore subsidiaries, the invocation of treaty anti-abuse rules with respect to offshore intermediaries, and the use of overarching general anti-avoidance measures to challenge varied structures that rely on offshore entities. These haphazard anti-avoidance rules are overlaid with revenue authorities' indignation at the motivations that underlie many corporate relocations. It is argued that a more coherent approach would be to focus on the objective reality or unreality of corporate establishment, by reformulating corporate residence in domestic law and tax treaties.

JUDr. Petr Kotáb International Aspects of Taxation in the Czech Republic SUMMARY Economic life of the current period is marked by high level of globalization of the economy and ever growing volume of cross-border flows of labor, goods, services and capital. In this situation, issues of international taxation affect not only sporadic cross-border transactions of selected types of subjects but virtually daily tax relations of large numbers of tax subjects, legal entities and individuals. Principles and regularities of international taxation are spreading in an ever growing extent into the intrastate level and are influencing the production of tax laws and everyday application practice of tax administrators. International aspects of taxation project into intrastate tax relations when there is a certain foreign element present in the tax relation. Such foreign element can show on the level of the subject of a tax relation (e.g. a non-resident taxpayer, permanent establishment, etc.), or the object (e.g. foreign-sourced income), or as the case may be, the tax relation content (e.g. tax liability imposed by a foreign state and the necessity to reflect it in the inland for the purposes of prevention of double taxation, e.g. by a credit method). A foreign element in the tax relation usually indicates the danger of...

The subject matter of the thesis is new as the phenomenon of the Box Corporation has not been the subject of a specialized investigation from the fiscal perspective before. A foreign subsidiary indirectly owned in a third country jurisdiction is in the thesis classified as a Box Corporation. The subject of the thesis is primarily to analyze and establish the following connections: the intended corporate objectives and ends and the modus operandi and the means that often require the Box Corporation as a necessary vehicle to attain those ends. The close connections between corporate law and tax law as intended legal results interdependent on one another. The application of the Box Corporation as an important vehicle for international tax planning by Swedish corporate groups on ever increasing competitive international markets and the special tax problems connected to the Box Corporation as it presents serious challenges to the pursuits for a consistent, neutral and undistorted Swedish corporate tax system. The thesis also investigates legislative and regulatory public reactions to the Box Corporation in the ways of CFC tax provisions, of denying tax treaty privileges by Limitation of Benefits clauses and of increasing domestic requirements on reportable transactions and international exchange of information and co-operation.

Since the mid-1990s, countries offering tax systems that facilitate international tax avoidance and evasion have been facing growing political pressure to comply with the internationally agreed standards of exchange of tax information. Using data of German investments in tax havens, we find evidence that the conclusion of a bilateral tax information exchange agreement (TIEA) is associated with fewer operations in tax havens and the number of German affiliates has on average decreased by 46% compared to a control group. This suggests that firms invest in tax havens not only for their low tax rates but also for the secrecy they offer. (authors' abstract) / Series: WU International Taxation Research Paper Series

The diploma thesis is focused on the international taxation and local taxation of employee in the Czech Republic and Germany. It includes the both, theoretical and practical interpretation, which is shown by using the model example. In this example is calculated tax for resident in both countries, and the related social security. Using the example verifies the hypothesis which says that the tax wedge for the taxation of married couples with two children is less than the tax wedge on individuals without children. Another goal is to show the differences in the calculation of tax and related deductions from the tax base, tax rate and tax credits. There are shown the differences in the calculation of tax and duties arising for employees in the case of resident and non-resident in both countries and also tax wedge on wage.

The main aim of the diploma thesis is to identify situations of mutual interaction between double tax treaties and domestic law of income tax, in these situations there is not only one interpretation. This interaction is described by many actual discussed issues, which exists on the field of the income tax. Theese discussed issues are primarily about permanent establishment, first issue is about permanent establishment according to the double tax treaty between the Czech republic and Germany, second issue is about permanent establishment according to the double tax treaty between the Czech republic and Ukraine, last discussed issue is about information obligation of permanent establishment according to the czech income tax act. The sources of theese problem are judgements, professional literature and professional discussion (KOOV).

This diploma thesis is focused on international tax planning and tax optimization of relaties parties. In the first part of the thesis are written theoretical bases, which are important for understanding the whole work. In the analytical parts are stated the factors that are decisive for international tax planning. At the end of the work is presented the process of international tax planning and tax optimization on a specific subject.

The Master’s thesis is focused on international taxation of dividends from the perspective of legal entities. With regard to the scope of the topic deals with, the thesis focuses only on taxation of dividends issued by holding companies. The Master’s thesis deals with description and analysis of the relevant legislation, that is international, union and domestic legislation. The knowledge of the analysis is applied in recommendations for holding companies.

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...