This thesis deals with taxation of permanent establishments and effect of transfer pricing regulation on method of attribution taxable profit to permanent establishments. Firstly, the thesis describes reasons for creation of permanent establishments and analyses how international and local legislation approaches to taxation of their profits. It also examines methods of attribution taxable profit to permanent establishments. Finally, the thesis analyses whether it is possible to use publically available data for determining tax base of "dependent agent" permanent establishment. For this purposes the following methods were used: regression analysis, cluster analysis and logistic regression analysis.

The diploma thesis describes in the first part the process of calculation of corporate income tax basis from the accounting profit and subsequently the calculation of corporate income tax according to the actual valid legislation in Czech republic. In second part the diploma thesis discusses the tax optimalization perfomed by companies which is actually significant problem for lots of states. On the concrete examples are described possible ways of tax optimalization related to both small and middle size enterprises and holding companies operated globally.

Recodification of income tax Accrual model of income determination - its advantages and disadvantages Abstract The aim of this thesis is to describe and evaluate the accrual system of determining the income tax base in connection with a possible recodification of Act No. 586/1992 Coll., Act of the Czech National Council on Income Taxes, as amended (the Income Tax Act), especially by describing the advantages and disadvantages of specific models of determining the tax base based on the accrual principle, i.e., dependent, semi-dependent and independent system. The hypothesis is the statement that the currently used semi-independent system for determining the income tax base (for those entities that determine taxable income on an accrual basis) in the Czech Republic is the most appropriate. The basic source and starting point of this thesis is a document prepared by the working group of the Ministry of Finance entitled "Innovation of income tax regulation", whose task was to prepare a new version of the Income Tax Act and which published the basic theses on the new bill for public consultation in October 2016 entitled Summary of Solutions for Innovation in Tax Regulation and Income Insurance (hereinafter referred to as the "Summary"). Although the intention to recodify the Income Tax Act is currently being...

Выпускная квалификационная работа (магистерская диссертация) посвящена выявлению, оценке и управлению налоговыми рисками на предприятии. Основной целью магистерской диссертации является предложение мероприятия по снижению налоговых рисков и рассчитать их экономическую эффективность для анализируемого хозяйствующего субъекта. / Final qualifying work (master's thesis) is devoted to the study of tax risks of a commercial enterprise. The main purpose of the master's thesis is to propose measures to reduce tax risks and calculate their economic efficiency for the analyzed economic entity.

A partir da decisão do Supremo Tribunal Federal proferida no julgamento da Ação Direta de Inconstitucionalidade 1851-4/AL, os entes políticos, especialmente, estados-membros, passaram a fazer uso pleno e generalizado do regime autorizado excepcionalmente pelo art. 150, § 7.º, da Constituição de 1988, dispositivo inserido no texto constitucional por meio da Emenda n.º 3/93. Trata-se do regime de tributação chamado de substituição tributária para frente, por fato gerador presumido, que abre exceção ao princípio da capacidade contributiva em nome da praticabilidade da tributação. E o objeto do presente trabalho é o estudo dos limites à instituição deste tipo de tributação. Diante da possibilidade de restrição ao princípio da capacidade contributiva, essa norma será o primeiro objeto de análise. Parte-se da teoria dos princípios, por meio da qual se distinguem princípios e regras por critérios estruturais para que se defina o direito fundamental à tributação conforme a capacidade contributiva. Distinguem-se dois direitos fundamentais relativos a dita capacidade, uma regra e um princípio, para, em seguida, focarem-se vários aspectos do conteúdo e aplicação desse princípio. Chegando-se à conclusão da aplicação conjunta do princípio da capacidade contributiva com o interesse coletivo na praticabilidade da tributação, passa-se à análise do instrumento de tal aplicação, que é o modelo da proporcionalidade, conseqüente da distinção entre princípios e regras e definição dos princípios de direito fundamental, como normas com limites definidos por circunstâncias externas ao seu próprio conteúdo. Ao final passa-se à análise de algumas possibilidades de aplicação da proporcionalidade na definição dos limites impostos aos legisladores ao instituírem regimes de tributação por fato gerador presumido. / Since the decision of the Federal Supreme Court on the judgement of the Direct Action ADI 1851-4/AL, the political entities, specially state-members, started to make plain and general use of the regime authorized exceptionally by the article 150, § 7.º, of the Constitution of 1988, clause inserted in the constitutional text by the third Emend (1993). It is a tax regime called forward tax substitution for constructed taxable event, that makes an exception to on the ability to pay principle based on the taxation practicability. The object of this essay are the limits of the use of this regime. Noticed the possibility of restriction to the ability to pay principle, this norm is the first object of analysis. It is started by the principles theory, by which principles and rules are distinguished on terms of structure, to then define the constitutional right to be taxed on the proportion of the ability to pay. Two different constitutional rights related to this ability are distinguished, a rule and a principle. Then, various aspects of the content and application of this principle are focused. After noticing the joined application of the ability t pay principle and the public interest on the practicability of the tax system, it passes to the analysis of the instrument of this application, the proportionality model, which is a consequence of the distinction between principles and rules and the definition of principles of constitutional rights, as norms with limits determined by circumstances out of their own content. Then, the work passed to some analysis of some possibilities of application of the proportionality model on the definition of the limits to the legislators to make use of regimes of taxation of constructed events.

Tématem této diplomové práce je aplikace Lafferovy křivky na daň z příjmů právnických osob v České republice. Trendem vrcholícím v posledních letech je snižování sazeb daně z příjmů korporací. Velice často se v této souvislostí mluví o fenoménu daňové konkurence. V souvislosti s očekávanými přínosy snižování daňových sazeb se práce snaží nalézt odpověď na otázku, jaký vliv má výše daňových sazeb na daňový výběr. Pro účely této analýzy je v práci vytvořen regresní model na základě časové řady dat o DPPO v ČR. Tento model umožní odhadnout daňový základ, který je použit k výpočtu daňového výnosu a konstrukci Lafferovy křivky. Na základě výsledků aplikace křivky na časovou řadu od roku 1997 se práce věnuje posouzení vhodnosti Lafferovy křivky jako nástroje k vysvětlení vývoje korporátních daňových příjmů v ČR. Následně je porovnáno daňové zatížení korporací v ČR se zatížením v ostatních státech EU, které rovněž sledují trend daňové konkurence. Analýza daňové zátěže korporací v rámci EU umožní vyvodit implikace pro oblast veřejných financí a růstový potenciál ekonomiky.

This thesis consists of five papers, which concern expenditure decisions and economic growth within Swedish local government.Paper [1] explores the hypothesis that local fiscal shocks have short run effects on revenue and expenditure decisions made within local government. It is found that although fiscal shocks do not affect local authorities' revenue decisions, they do induce municipalities to change expenditures and financial costs along with short term loans. Local authorities are also found to respond more powerful to unfavorable fiscal shocks (deficit shocks) than to favorable fiscal shocks (surplus shocks).In Paper [2], we study the hypothesis that local (municipal) expenditures, in part, can be explained by regional (county) expenditures. We formulate and estimate a demand model for municipal services that is defined conditional on the county expenditures. The results imply a positive dependency between the provision of county and municipal services. Moreover, the results suggest that the hypothesis of weak separability between the provision of county and municipal services can be rejected. In addition, we cannot reject the hypothesis that the regional expenditures are weakly exogenous in the local expenditure equation.In Paper [3] the existence of spillover between Swedish municipalities in the provision of recreational and cultural services is analyzed. A representative .voter model is derived and the demand for recreational and cultural services is estimated using spatial SUR techniques. The results suggest a negative relationship between recreational and cultural expenditures provided by neighboring municipalities, which indicates that these services are substitutes.Paper [4] concerns the regional growth pattern in Sweden by analyzing what factors might determine the growth rate of regional average income levels and the net migration rates. Our results suggest a negative dependence between the initial average income level and the subsequent income growth, which supports the conditional convergence hypothesis. Among other things, we also find that the initial endowments of human capital have a positive effect on subsequent net migration while the initial unemployment rate is found to have a negative impact on net migration.Paper [5] complements the analysis made in Paper [4] by studying which factors determine average income growth and net migration at the local level of government. The conditional convergence hypothesis cannot be rejected. Local government investments are found to have a positive effect on the subsequent net migration while leaving the growth in mean income unaffected. This may indicate that the net migration caused by these investments does not significantly affect the proportion of skilled and unskilled labor. / <p>Härtill 5 delarbeten.</p> / digitalisering@umu

Paper [I]- Household Migration and the Local Public Sector: Evidence from Sweden, 1981-1984 (co-authored with Michael L. Wyzan), contains an empirical explo­ration of the nexus between variables related to the local public sector budget and migration. Micro-data is employed in binomial and multinomial-logit regressions esti­mating the probability to migrate. We report results separately for metropolitan and nonmetropolitan areas, because the per capita levels of the tax base and intergovernmen­tal grants are theoretically important migration determinants where population is sparse, while the tax rate may be more important where population is dense. Empirical results support our fiscal hypotheses and are consistent with previous findings on household characteristics. Paper [II]- Internal Gross Migration in Sweden: The effects of Variation in Mobility Grants and Regional Labour Market Conditions, focuses on the effects of labor market conditions and migratory stimuli on over county-border migration. Aggregate data on the flows of all migrants and on the flows of migrants receiving extra mobility stimuli are used in estimations of a single-equation migration model based on the hiring function. The results indicate that regional migration flows respond to changes in labor market conditions in accordance with predictions from economic theory. This result seems mainly to stem from the migratory behavior of the unemployed. In addition, nonmatching migration subsidies at the levels employed are not found to be migration enhancing. Paper [IH]- Employment Opportunities, Wages and Interregional Migration in Sweden 1970-1989, deals with the impact of aggregate labor turnover and regional labor market conditions on gross in- and outmigration. Annual panel data is used in estima­tion of separate in- and outmigration functions, where regional labor market conditions are assumed to be endogenous with migration under two different assumptions concer­ning the working of the labor market. An increase in the regional excess supply of labor is found to increase outmigration and decrease inmigration. Moreover, cyclical variation in labor turnover is positively correlated with gross migration. The hypothesized effects of real wages on migration are not confirmed. The results are not sensitive to the various assumptions concerning regional wage formation considered in this study. Paper [IV]- A Panel Study of Migration, Household Real Earnings and Self-Selec- tion (co-authored with Roger Axelsson). The effects of migration on household real earnings are examined. Data pertain to a sample of stable household constellations in Sweden, 1978-1991. A treatment-effect model is employed, whereby the potential effects of nonrandom sampling of data on earnings for migrants and nonmigrants are taken into account. We find that stable multi-adult household constellations did not gain in income from migration during the 1980s. In addition, we find no strong indications of selection bias in the income equation. / digitalisering@umu

The diploma thesis "Tax implications adjusting the profit to the tax base of corporate income tax" focuses on the formulation of recommendations of legal tax optimization leading to the reduction of the tax base of the selected entity. The main direction of optimization is the management of costs, which, with their character, contribute significantly to the formation of the tax base. The thesis is divided into the theoretical and practical part. The theoretical part will allow to get knowledge of corporate income tax in the general legal regulation of the Czech Republic. In addition, there is the process of transformation of the economic result in the tax base with the identification of areas of legal tax optimization based on the Income Tax Act No. 586/1992 Coll. In the practical part, there is the application of acquired knowledge to the real data of ABC, s.r.o. Subsequently, the optimization options are proposed to reduce the tax burden so that their economic substance has a real meaning for a given entity. At the end of the thesis the recommendations are generalized for wider practical use.

I decided to devote my thesis to the optimalization of tax burden of income tax {--} the legal tax avoidance. The main aim of this work is to point out legal possibilities how to abate the tax base of the income tax and tax liabilities of natural persons, which enables the curently valid law of income tax, as well as other rules and regulations conditioning taxation. My partial aims are to compare particular variants abating the tax base and the personal income tax, to evaluate the best possibilities and to illustrate their practical solutions on concrete situations. The thesis is divided into three main parts. In the first part I mentioned the main significance of taxes in the budget of the Czech Republic and the incorporation of the personal income tax into the tax system. Next, I tried to clear up the mater of the personal income tax, as for example who a tax-payer is, what the object of the tax is, what belongs to the tax base, what tax rebates and nontaxable parts of the tax base are, how to calculate the tax. It concerns in particular tax-deductible items, re-deduction of property, reserves, the way of financing new property, lump expenses, collective taxation of spouses etc. The last part is focused on presentation and practical solving of problems. I tried to include such examples which concern great number of tax-payers or which are most often used in practice.