A arquitetura do Sistema Humanitário Internacional no século XXI está em expansão. Não somente os recursos aportados têm crescido, como também o número de atores envolvidos como doadores, tais como organizações internacionais governamentais e não governamentais. Os países são os maiores provedores de assistência humanitária, e este grupo também apresenta ampliação. Tradicionalmente, os países membros do Comitê de Assistência ao Desenvolvimento, da Organização para Cooperação e Desenvolvimento Econômico (DAC/OCDE) são os atores mais antigos do sistema humanitário contemporâneo e os que mais aportam recursos. A literatura recente, contudo, aponta para a emergência de outros países doadores de fora do grupo, que estariam trazendo mudanças na governança internacional do sistema. Os estudos sobre os doadores \"Não DAC\" carecem de dados precisos, sendo, em sua maioria, baseados em estimativas. Esta pesquisa visa a aprofundar os conhecimentos sobre a atuação desses doadores, valendo-se de estatística descritiva de dados primários de organizações multilaterais do sistema humanitário da Organização das Nações Unidas para se poder mais bem compreender o grau de participação financeiro que os doadores \"Não DAC\" agregam ao sistema. Além disso, o estudo apresenta uma análise de como o Brasil age como doador de assistência humanitária internacional. / The architecture of the International Humanitarian System in the 21st century is expanding. Not only the resources contributed have increased, but also the number of actors involved as donors, such as international governmental and non-governmental organizations. Countries are the largest providers of humanitarian assistance, and this group is also expanding. Traditionally, the member countries of the Development Assistance Committee of the Organization for Economic Co-operation and Development (OECD / DAC) are the primary actors in the contemporary humanitarian system and those who provide the majority of the resources. Recent literature, however, points to the emergence of other donor countries outside the group that might be bringing changes in the international governance of the system. Studies on \"non-DAC\" donors lack accurate data and are mostly based on estimates. This research aims to deepen knowledge about the performance of these donors, using descriptive statistics on primary data from multilateral organizations of the United Nations humanitarian system to better understand the degree of financial participation that \"Non-DAC\" donors add to the system. Furthermore, the study presents an analysis of Brazil\'s actions as a donor of international humanitarian assistance.

The aim of this thesis is to analyse the impact of the application of § 38f article 4, which is the Czech legislation allowing the resident to use exemption method for the taxation of foreign income from employment regardless of the method provided in the relevant Double Tax Treaty. The thesis includes an analysis of the development of the taxation of income from employment in the Czech Republic with regard to the taxation of foreign income. Further analysis of the evolution § 38f article 4 of the Income Tax Act and Article 15 of the OECD Model Treaty. The thesis conclusion states that in the model cases, if the foreign country uses a lower tax rate than is used in the Czech Republic, it is always advantageous to use the exemption method for taxpayers. In the case of higher tax rate it appears to be more favourable credit method in the most cases.

The external debt is no doubt "a front burner" nowadays, not only in the group of well informed economists or politicians. And although it is regarded as a problem ascribed to the third world countries only, any national economy can bear it. Anyway, neither developed countries are exceptions, despite distinctly small attention which is given to them from the external indebtedness point of view. In my thesis, I decided to link the foreign debt problem with another frequent topic of any discussions: with the really prudent process of the European Union expansion to the East. Primarily, I will try to confute many skewed information about both of them. Or - is the foreign debt really such an uncompromising indicator of the external instability hindering any economic progress? Must thus the relatively successful transformation of the transitive economies pass off with the zero foreign indebtedness entirely?

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The diploma thesis deals with comparision selected property taxes in the Czech Republic and Poland. The work is divided into five parts. The application aim of work is calculated the tax liability for selected agricultural company in the Czech Republic and its comparing with Republic of Poland. Another aim of this thesis is compared the productiveness of property taxes within selected OECD countries.

Bedienstete Internationaler Organisationen stehen in einem speziellen Rechtsverhältnis zu ihrem Arbeitgeber, das ihnen ermöglicht, belastende Maßnahmen von speziell für Personalrechtsangelegenheiten errichteten internationalen Verwaltungsgerichten (Administrative Tribunals) überprüfen zu lassen. Anläßlich einer konkreten Streitigkeit (ESA) um Gehaltskürzungen befaßt sich der Beitrag sowohl mit prozeduralen als auch mit materiell-rechtlichen Fragenstellungen und erörtert, wie weit hier bereits allgemeine Rechtsgrundsätze existieren.

The subject of the diploma thesis is to establish safe harbours for management fees. Safe harbours as a transfer pricing scheme are based on the Transfer Prices Guide-lines for Multinational Enterprises and Tax Authorities from 2017. This scheme entails simplification for businesses, which should reduce the burden on businesses in the production of transfer pricing. The work mainly focuses on setting safe harbours for a fairly controversial area of management fees and the safe harbours are based on setting the usual market margins for selected management services.

Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. To predict whether the multilateral reform effort will be successful, it is important to examine the nature of the multilateral negotiating process itself, because every negotiation is shaped by its context.  But this context is not static—rather, the nature of tax multilateralism varies depending on certain global conditions. Sometimes, it is a hierarchical process, dominated by powerful countries operating in a closed-club of developed states spearheading the effort, while weaker countries must tag along and accept the eventual outcome. Alternatively, multilateralism may be egalitarian and inclusive, with many countries—strong and weak alike—contributing to the debate, accepting tradeoffs, and endorsing the outcome. In this thesis, I demonstrate that the nature of tax multilateralism has changed from the former model to the latter by comparing the negotiation of the OECD Model Tax Conventions with the Pillars Negotiation. I begin by identifying several factors that influence the nature of tax multilateralism: first, the distribution of global power among states; and second, the level of integration of the global economy. In an international system where power is concentrated in a few states, and the international economy is fragmented (i.e., the conditions of the 20th Century), multilateralism tends to be hierarchical and exclusive. However, when power is diffused and the global economy is integrated, (the conditions of the 21st Century), then multilateralism is egalitarian and inclusive. In such a context, international tax issues—like base erosion and profit-shifting—are so vast and complex that no state, acting alone or in a small group, could deal with them. The thesis thus concludes that the nature of tax multilateralism has changed, because in modern negotiations, powerful states are both less capable of dominating other states in the negotiating process and are highly dependent on a successful outcome that creates global consensus.

New Public Management has been the prevailing governance model in public sector administration since the late 1980s. In 2005, OECD-DAC member states adopted the resultsbased management model ‘Paris Agenda for Aid Effectiveness’, building on new public management theory and values. The aim was to achieve more effective aid by coordinatingand harmonising donor efforts, aligning development interventions and funding, supporting national ownership and propelling a result- and accountability culture by demonstrating achievements.Despite its worthy ambitions the Aid Effectiveness Agenda has paradoxically failed todeliver on its own outcomes. The results-based management framework underpinning theagenda has proven to be highly complex in methodology, interpretation and application. The framework is laborious and burdensome, diverting time from ‘ordinary’ work and risking a bureaucratization of the development aid sector. The ‘measurement fever’ has grippeddonors and agencies alike, and is now mainly driven by donors’ domestic accountability concerns, rather than the real needs of developing countries. More alarmingly, it has not onlyhad numerous unintended consequences but also outright adverse effects. This in turnen dangers long-term human development.This study sets out to explore to what extent the results-based management framework, based on new public management theory, has been a suitable management model to achieve aid effectiveness in the development aid sector. It departs from the governance theories of Denhardt and Denhardt (2000) and assesses whether New Public Service couldbe a fitting alternative governance model. The study utilizes the realist review methodology,specifically the CMO-configuration, in order to explore how context and mechanisms interact and how this affects the outcome. This study has through its aggregative and configurativeambition explored 26 scholarly articles in the time frame of 2011 to 2021 in order to draw conclusions.The review has found that the results-based management framework does not support the underlying theory of change that is imperative to achieve the Aid Effectiveness Agenda.Contextual factors are found to impede implementation, although due to being under research edit is difficult to determine to what extent. Further, none of the five mechanisms ofthe Paris Declaration can neither fully nor partially be said to contribute to ‘aid effectiveness’as defined in the Aid Effectiveness Agenda. Rather, the review has found that the literatureall point to numerous adverse effects of its implementation.This study concludes that the New Public Service governance model, at least intheory, could prove to be a more suitable management model for the development aidsector. Since the sector is neither linear nor predictable as the business sector for whichthe framework was developed, it is not surprising that adverse effects abound. Especiallysince the development aid sector is highly complex with a multitude of actors, politicalincentives and not least challenging implementational environments. In contrast, New Public Service places the citizen at the centre and aspire at buildingdemocratic citizenship and community through citizen participation and dialogue. Such analternative governance model built on democratic theory and participative epistemologyhas the potential to democratize governance practices by replacing the vertical top-downprincipal-agent dynamics of new public management with more horizontal forms of citizeninvolvement, co-determination and mutual accountability. New Public Service stresses the‘serving not steering’ aspect of governance, which would open up for a more authenticdiscourse of recipients owning development in their own society and setting the direction.No systematic review has previously been carried out to assess governance models inrelation to achieving the Aid Effectiveness Agenda. In fact, there is very little research onwhat has worked or not regarding the agenda. This thesis sets out to fill this gap and tocontribute to the discussion of governance models on a theoretical level. It is also anempirical contribution to applied development management regarding insights about whatcontexts and mechanisms affect aid effectiveness.

Development cooperation is nowadays a highly discussed topic, especially in the context of its effectiveness. In the past years the European Union and the Organization for economic cooperation and development adopted several documents concerning aid effectiveness and possible ways of its improvement. The aim of this thesis is to find out, in the case of selected states (France, Sweden, and the Czech Republic), if they implement the commitments resulting from these documents into their national development policies and if they carry out their development cooperation in compliance with them. Since the commitments in this area overlap between the two organizations and both of them are trying to influence the states to fulfill their commitments, this thesis will also try to identify which of these organizations has a greater influence on the chosen states. Keywords EU development policy, Council Conclusions, Member States, OECD, aid effectiveness, financial commitments