This article describes and analyses the present conditions of the application of the Public Work Tax Deduction (PWTD) mechanism, identifying six main obstacles that difficult on a appreciable way his concrete implementation or the rate of it.For this purpose, this study has identify and analyze the 30 main highlights that conform the critical path of PWTD process, determining the actual times for his performance and comparing them with the legal times established on the PWTD actual law, and so with the optimal times reasonably according with the experience on the public management of similar work projects. / El presente artículo describe y analiza las condiciones actuales de la aplicación delmecanismo de Obras por Impuestos (OXI), identificando seis obstáculos principales que dificultan de manera apreciable su implementación concreta o la velocidad de la misma. Para efectos del presente estudio se han identificado y analizado los principales 30 hitos que conforman la ruta crítica del proceso OXI, determinando los tiempos reales para su cumplimiento y comparándolos con los tiempos legales establecidos en la normativa OXI actual, y con los tiempos óptimos estimados razonablemente de acuerdo a la experiencia en la gestión pública de proyectos similares.

This diploma thesis was aimed at analyzing the influence of tax incentives for the research and development on the tax duty of the taxpayers. Within the first section a term research and development was defined followed by the specification of possible forms of the tax incentives for the research and development. The calculation of the tax duty of the illustrative company which effected research and development activity (within two scenarios) was presented within the practial section. The illustrative company was constantly profitable in the first scenario and as such, it incurred higher savings from the application of the research and development tax deduction in comparison to the second scenario (where company incurred a tax loss in one taxable period). Based on the results, taxpayers who apply the research and development tax deduction may consider a tax optimisation in case they could possibly incur a tax loss.

Research realised by the public sector leads to new knowledge. To achieve economic growth of the country, it is necessary that the results of such research could be useful for innovation in the private sector. It can be achieved by cooperation of both sectors. The government of the Czech Republic supports such cooperation since 2014, through the option for businesses to include costs of R&D services and intangible results of R&D purchased from public universities or public research institutions in the tax deduction for research and development. It can be also better used by small and medium enterprises, but the total amount of this tax incentive decreased in 2014 as compared with 2013. The aim of this diploma thesis is to analyse the reasons for the low utilization rate of tax deduction for research and development and low levels of cooperation on R&D between enterprises and public sector, primarily universities.

Diploma thesis is focused on tax deduction of vocational education. The thesis analyses reasons for the introduction of tax deduction. These were for example trends in education in the Czech republic after year 1993, as well as employers´ demand on skilled employees. Beside the description of legislation of tax deduction of vocational education, diploma thesis describes how the vocational education is supported abroad. The last part of diploma thesis analyses employers´ opinions on tax deduction of vocational education, that were obtained from questionnaire.

The thesis examines the influence of the tax deduction by reason of granting the donation on the taxpayers' behavior. The examination is working with Household Expenditure Survey (2004, 2005) of Czech Statistical Office and with author's own questionnaire survey (2007). In the first part the regression of demographical and economic characteristics on the amount of donation and its probability is run. There are the internal opinions of informant according to the filled questionnaire described in the second part. The regression was processed using Logit, Probit and Tobit models; the following section consists of frequency analysis.

The diploma thesis deals with the issue of value added tax. Its correct application under the Value Added Tax Act No. 235/2004 Sb. In concrete cases, which are subsequently listed in the practical part of this diploma thesis on selected companie and their business operations. The conclusion of this thesis is the assessment of the problems and proposals of tax optimization, the reduction of the tax liability as allowed by the legislation.

This diploma thesis deals with evaluating of research and development projects from the viewpoint of income taxes in business corporation. The thesis defines legislation of the problematics. On the basis of acquired knowledge a methodological guide is created. It can be used in business corporation while evaluating research and development projects in accordance with income taxes. In this diploma thesis the chosen research and development projects in existing business corporation are solved by the created methodological guide. Illustrative examples of situations which can appear during realization of research and development projects and its financial impacts on business corporation are given at the end of this thesis.

The Public Works Tax Deduction Law has been enacted to foster public investment at a local and regional level by including participation from the private sector and through the subscription of agreements with local and regional governments.Nonetheless its noble purposes, in the application field of the Law, normative gaps are put into evidence, which impede its practical application. In the present article, the author shows which are the Law’s deficiencies, while analyzing them and proposing possible solutions. / La Ley de Obras por Impuestos tiene como objetivo principal impulsar la inversión pública de impacto regional y local, con la participación del sector privado, mediante la suscripción de convenios con los gobiernos regionales y/o locales.No obstante su noble propósito, en el ámbito aplicativo de la ley se evidencian ciertos vacíos normativos que dificultan su aplicación práctica. Es así que –en el presente artículo– la autora nos muestra cuáles son estas deficiencias a la vez que, luego de hacer un análisis de las mismas, nos propone posibles soluciones.

Submitted by Guilherme Pereira das Neves NEVES (gneves@nseb.com.br) on 2017-12-08T13:43:30Z No. of bitstreams: 1 GUILHERME NEVES - 08.12-versão final pós banca - 06-12-2017 (00088671xDAE77)-1 (002).pdf: 2533438 bytes, checksum: e1de02bc7e0a2aae008c392a5cbfae68 (MD5) / Approved for entry into archive by Joana Martorini (joana.martorini@fgv.br) on 2017-12-08T14:28:50Z (GMT) No. of bitstreams: 1 GUILHERME NEVES - 08.12-versão final pós banca - 06-12-2017 (00088671xDAE77)-1 (002).pdf: 2533438 bytes, checksum: e1de02bc7e0a2aae008c392a5cbfae68 (MD5) / Made available in DSpace on 2017-12-08T16:37:51Z (GMT). No. of bitstreams: 1 GUILHERME NEVES - 08.12-versão final pós banca - 06-12-2017 (00088671xDAE77)-1 (002).pdf: 2533438 bytes, checksum: e1de02bc7e0a2aae008c392a5cbfae68 (MD5) Previous issue date: 2017-11-13 / A legislação fiscal brasileira estabelece como condição necessária para a dedução fiscal do ágio pago na aquisição de participação em empresas brasileiras a ocorrência de evento especial de incorporação. Diante dela, investidores não residentes constituem holdings no país, as quais (i) ou realizam diretamente as correspondentes aquisições, ou (ii) servem de receptoras da participação societária adquiridas ordinariamente por suas controladoras no exterior. As referidas holdings são posteriormente incorporadas pelas empresas operacionais cujas participações societárias foram adquiridas, de modo que estas passam a deduzir fiscalmente o ágio. A Receita Federal do Brasil (RFB) entende que a utilização de sociedade holdings nesse contexto é artificial, uma vez que este tipo de estrutura societária oculta o real adquirente do investimento. Por esta razão desconsidera as referidas sociedades para fins tributários. Nesse contexto, a presente pesquisa pretende demonstrar que o ato de requalificação empreendido pelas autoridades fiscais, se considerado válido, gera como consequência jurídica ofensa à regra de não discriminação prevista no art. 2º da Lei nº 4.131/62, assim como ao princípio constitucional da igualdade tributária previsto no art. 150, II, da CF/88. / Brazilian tax law establishes as a mandatory condition for tax deduction of the goodwill paid upon the purchase of equity interest in Brazilian companies the occurrence of a special merger event. In view of that, non-resident investors incorporate holding companies in Brazil which either (i) perform the corresponding purchases directly, or (ii) serve as receivers of the equity interest originally purchased by their parent companies abroad. Said holding companies are subsequently downstream merged into the operating companies whose equity interests were acquired, and as a result they can deduct the goodwill paid for tax purposes. The Brazilian Federal Revenue Office ([Receita Federal do Brasil (RFB)] understands that the use of holding companies in that context is rather artificial, to the extent that this type of equity structure disguises the actual purchaser of the investment. For that reason, it disregards said holding companies for tax purposes. In this context, this research is intended to demonstrate that the act of requalification performed by tax authorities, if deemed to be valid, generates as a legal consequence the violation of the non-discrimination rule established by article 2 of Law No. 4,131/62 [Lei 4.131/62], as well as the constitutional principle of tax equality provided for by article 150, II of the Federal Constitution of 1988.