The main topic of this thesis is double taxation - the issue which gets more and more important, because national economies are going to be connected and international business develops, double taxation affects these activities strongly. Double taxation is considered to be negative phenomenon not only by private sector, but even states, so we can detect efforts for elimination or even reduction of this negative phenomenon. Because double taxation is very large topic it is not possible to cover it comprehensively, this diploma thesis is reduced only to some spheres and institutions of double taxation. The thesis is composed of three main parts. Theoretical introduction to the issue of double taxation mentiones the most important terms and principles of the double taxation and constitutes the basic for the following interpretation. Meaned are methodes and means used to eliminate double taxation with the practical example of their use and their comparison. The second chapter deals with internal aspects of double taxation and focuses on the Czech and EU legislation of double taxation. Attention is also paid to the Czech future double taxation elimination legislation of income from shares in profits and from similar profits and to its' consequences. The third chapter is concerned with international...

The aim of diploma thesis is to analyze realization of a Convention for the avoidance of double taxation between the Czech Republic and the Republic of Austria. The paper explains what the international double taxation is and describes the types and methods of its prevention. It describes difference between tax residents and tax nonresidents. Further it describes development of Conventions for the avoidance of double taxation between the Czech Republic and the Republic of Austria and compares the Convention No. 48/1979 and No. 31/2007 which were applied in mutual tax relations between both countries. The paper is mainly focused on the situation of Czech tax residents who receive incomes from employment in Austria and shows on practical examples how the situation developed from 2007 to present. It describes the complicated situation of taxpayers in 2008, when they first proceed according to a new Convention between both countries and explains the calculation of the "super-gross wage" when incomes are from employment abroad. The paper also describes the approach to Austrian taxation of interest payments and resolve procedure Czech taxpayers in these cases. Finally, this paper examines the attitudes of both countries to adhere to Convention for the avoidance of double taxation and describes the difficult situation of Czech taxpayers with incomes from Austria.

This work provides a basic orientation in matters of taxation of non-residents - natural persons in the Czech Republic. At the beginning are explained the concepts, methods to avoid double taxation, and examines the various categories of income taxation of individuals and also affects the social and health insurance. In the practical part are a questions addressed to the specific practical examples, including file and completing tax return, social security and health insurance reports and other related forms. In conclusion are mentioned the news regarding the taxation of non-natural persons and author´s proposals. The work shows the possibility to limit tax evasion carry out the transition from the system of automatic oneself declaration to the tax international refund system. There are added also useful attachments.

The content of the paper is to model new company in the American state, Nevada and its operation from the Czech Republic over the Internet. In this thesis is included theoretical resources, analytical section discusses the types of companies in the USA, the tax liability of companies related to the USA legislation and the final section proposes solution together with a cost calculation to establish a new company. And also which kind of services are used for doing business in the USA over the Internet.

The diploma thesis deals with the issue taxation of royalties. The thesis describes the legislation that is affecting the taxation of royalties. These are the international, union and internal legislation which are mutually compared with each other. In proposed methodology is presented the application process of the relevant legislation. Subsequently are solved the practical examples that deal with the issue taxation of resident and non-resident of the Czech Republic with revenues from royalties.

The aim of this thesis on the topic of the International double taxation of individuals is to offer particular point of view on this issue to the reader and make him acquainted with some current problems related to international taxation of income. The first chapter is focused on czech income tax, especially on taxation of individuals with its goal to define basic terms. Next chapter is concentrated on term double taxation and describes main reasons for its existence. Concurrently are described unilateral and international measures to eliminate double taxation of income and also methods for elimination of double taxation. Afterwards this thesis attends to bilateral international tax conventions and its evolution and interpretation. Considering the fact that majority of all concluded tax conventions are inspired by OECD model tax convention, the third chapter of this thesis is focused on the importance of the OECD model and its commentary for interpretation and application of bilateral international tax conventions. The last and main part of this thesis analyses several sorts of income in the same manner as they are categorized in OECD model tax convention. With respect to OECD model's classification of income from independent personal services as business profits, more attention is paid to this...

The master´s thesis deals with taxation of Europen Union residents in the Czech Republic. The main aim of this thesis is to create a methodology for the taxation of European Union residents incomes from employment in the Czech Republic. Attention is also moving to a model case of European Union residents, who receives incomes from employment in the Czech Republic during the tax year 2016.

This diploma thesis deals with the international hiring out of labour force between the Czech Republic and other member states of the European Union. It focuses on hiring out of employees between parent companies and subsidiaries. This diploma thesis describes the situation of the international hiring out of employees, suggests method of taxation of these employees and defines subjects responsible for fulfilment of obligations in the area of income tax and social security.

This diploma thesis deals with the obligations for implementing the construction project in the Slovakia and its taxation. At first is defined basic terminology, concept of single market of the European Union and the harmonization process of direct and indirect taxation. In the analytical part of the thesis are relevant sources of international, union and national law analyzed. The practical part is focused on specification construction contract, accomplishment all obligations and an exemplary taxpayer's tax liability is calculated.

The thesis deals with international cooperation in the fight against tax evasion in the field of direct taxation at the level of OECD and EU. First, the thesis explains why international tax evasion occurs, what the most common forms of tax evasion are and also how multinational companies use international, sometimes even aggressive, tax planning to reduce the tax burden. The next section specifies diverse measures already adopted within the OECD and the EU and also those that are still in preparation. Any action taken at the international level is put into context with what the Czech Republic has already introduced. Mutual exchange of information between countries is one of the most important tools in the fight against tax evasion. That is why an analysis of spontaneous exchange of information and on request between CZ and other cooperating countries was carried out in the last part of the thesis. The analysis was carried out on the basis of publicly available data from Annual Reports of Financial Administration of the Czech Republic and also on the basis of data which were received from the Department of international tax cooperation - direct taxes of General Financial Directorate.