This diploma thesis analyzes several aspects of taxation when entering a foreign market. The first chapter explains the difference between nominal and effective tax rates and tax burden regulation by enterprises during the current debt crisis. The second chapter deals with double taxation agreements and methods that eliminate double taxation. The third chapter describes the rules of transfer pricing and advance pricing agreements. The last chapter focuses on tax incentives and risks of taxation, especially tax avoidance, tax evasion and the negative attitude of developed countries against tax havens.

The Master thesis deals with the analysis of tax havens, their origin and operating mechanisms. The thesis will elaborately describe individual entities advantaged in terms of taxes and specific ways of using offshore and onshore centers in order to achieve tax optimization, ownership anonymity, property protection or any other partial goal. The first part is theoretical and some basic terms related to this topic are defined in it. In the second part, the practical use of tax havens is discussed. In the first chapter, I described four selected jurisdictions in detail, and in the second and third chapters, I specifically illustrated how a company founded in an appropriately chosen tax haven can be utilized in achieving a predetermined goal.

Thesis deals with the accounting and tax environment for business in the Netherlands and seeks to highlight the differences in legislation in comparison with the European trend. The work describe regulation of business and the related accounting and tax legislation. It focuses on group and tries to provide the answer to the question why the Netherlands is regarded as tax haven. There is obvious growing pressure of the European Union, the Netherlands implements IFRS principles to national accounting standards known as DAS. Although some issues still keep the original national treatment. Fiscal adjustments have a distinctive character, the country is an attractive destination in terms of taxation of dividends, interest, royalties and other capital gains.

International tax planning deals with the tax benefits, their seeking and using by the tax entities and corporations. Even if the tax havens are generally considered as small islands, the different types of tax advantages are offered by the developed countries of the North America or Europe. This paper focuses on the analysis of the inward of foreign direct investments into the European countries with the preferential tax regimes. It explains the relationship between the inward of the investments and the factors which affect them. The inward of the foreign direct investments is the dependent variable, the independent variables are tax rates on corporate income, unemployment, as well as political stability. Although results of econometric analysis did not confirm our initial hypothesis that the lower tax burden will increase the inward of the investments to the country, this increase can be caused under the other circumstances, such as secrecy, property protection, stable political situation or simplicity and utility of the financial markets.

The aim of this diploma thesis is to optimize the concern in terms of taxes. Model situations should point to tax optimization by moving business to tax havens. Diploma thesis deals particularly different taxation of concern in tax havens. The result of the work will be a proposal and recommendations for the establishment of a company in a tax haven.

In 2016, the ICIJ independent organization released the leaks of the Panama Papers. Using the data presented, this thesis aims to evaluate and examine the models developed for the quantification of money laundering, analyze the variables that define the appeal of certain tax havens, and develop extensions to the Walker-Unger model. The proportion of illicit funds flowing from a source country to a host country was calculated using the Walker-Unger model as a reference while considering 35 source and 10 host countries. The variables were adjusted for statistical analyses input through multiple fractional probit regressions, and the outcome was compared to the original Walker-Unger estimates. At a 5% significance level, the research found significance between the account proportion and the independent variables. Furthermore, the evidence showcased more significant values obtained with the regression model, implying that the Walker-Unger model has become irrelevant in this modern era. Due to the following reasons, this study provides a perspective into improving the model through several recommendations.

Thesis focuses on the possibility of setting up business entities in tax havens and their utilization in tax optimization. Reader is introduced to the most interesting Offshore and Onshore localities, their advantages, risks and possibilities of use. I will clarify the nature of the tax advantages of various types of companies including explanations of terms come from angloamerican jurisdictions. I will describe the specific steps which are required to set up the company in Grenada, including Sample documents and a model example demonstrating the tax optimization of the hypothetical bussines company. The resulting structure of the company will be subject to lower tax burden and consequently increase competitiveness of its products in global markets.

This thesis focuses on the use of destinations with moderate rate of corporate tax to reduce the tax burden of the business entity. It contains defined context and fundamental concepts and there is also an analysis of the current state of offshore business and restrictions aimed against its abuse. Thesis contains draft of business structure that ensures reduction of tax burden of the business entity, and which is followed by a definition of the benefits and risks of its application.

The master´s diploma thesis Tax Havens and Their Utilization deals with the respective problematic of tax havens and characteristics of chosen companies with their advantages. The first part of the work characterizes crucial notions and tax havens. The second part depicts chosen tax havens. The next part of the diploma thesis focuses on an example of taxation of a company with the following recommendation for a choice of a convenient tax haven for establishing a company.

依現行所得稅法規定，只要受控外國公司盈餘未匯回，即可享有「租稅遞延」的效果，由於近十年臺灣利用受控外國公司，對大陸間接投資金額占全部對外投資總額比重超過五成以上，又因上市公司投資金額較大且具有代表性，因此本論文以國內上市公司利用受控外國公司，間接投資大陸子公司為研究對象，探討國內上市公司是否有透過「受控外國公司」不分配盈餘，藉由稅法「漏洞」以產生遞延課稅之效果，及我國若是建立受控外國公司課稅制度，對我國上市公司投資大陸子公司其損益稅負之影響。 　　本文研究結果，發現國內上市公司利用受控外國公司投資大陸子公司，普遍存在有盈餘卻不分配且不匯回之現象，我國有建立受控外國公司課稅制度之正當性及必要性；且我國如建立受控外國公司課稅制度，以產業別而言電子產業受影響最大，以研發強度而言，研發強度在5%~7%及9%以上之企業有較大之影響。又雖然實施受控外國公司課稅制度後，對於中等規模(資本額50億至100億)之有效稅率增加幅度最大，但受影響而應繳納稅負之金額仍以大型規模之企業為最高。 　　因此我國建立受控外國公司課稅制度，能拉近不同特性企業間適用有效稅率的差距，對舉債投資得扣除利息費用，境外投資收益卻能遞延課稅，以及在台灣享有研發投資抵減利益，卻有高額境外所得保留在海外未匯回台灣課稅之公司，有一定衡平作用，則我國建立受控外國公司課稅制度，實已非僅財政收入之考量而已，相對而言，改善租稅公平才是具有更大的意涵，因此有其正當性及必要性。文末提出幾點建議，期能作為政府研擬受控外國公司課稅制度之參考。 關鍵詞：受控外國公司、租稅庇護所、多國籍企業 / According to the current provisions of the Income Tax Act, Taiwanese companies will benefit from the "tax deferral" by not unremitting overseas earnings of their controlled foreign corporations (CFCs). Since the last decade in Taiwan, many companies have been increasing investments in Mainland China via their controlled foreign corporations, the investment in Mainland China have accounted for over half the Taiwanese total foreign investments. Therefore, this study focuses on the Taiwanese listed companies which invest indirectly in Mainland China. Furthermore, the controlled foreign corporations have become a tax loophole; this study examines whether those listed companies leverage the tax loophole to gain the tax benefit through the "tax deferral of Chinese subsidiary earnings." Besides, this study estimates the potential impacts on the profit and tax costs of the mainland subsidiaries of Taiwanese listed companies, if the controlled foreign corporation (CFC) tax system will be established in the future. 　　The results of this study show that the majority of Taiwanese listed companies do not fully distribute and remit the Chinese subsidiary earnings back to Taiwan. Hence, it is necessary for Taiwan to establish the controlled foreign company tax system to close the tax loophole. As to the impacts on industries, the electronics industries will be most affected by the CFC tax system, if established. In addition, companies whose R&D intensity range from 5% to 7% and over 9% will also be significantly influenced. Although the effective tax rates of medium-sized companies will have the highest increase in effective tax rates, but large companies will have the highest increase in the amount of CFC tax. 　　Therefore, the establishment of CFC tax system will contribute to narrowing down the gaps in effective tax rates between different firm characteristics of companies. Moreover, the new tax system can help prevent companies from shirking their fair shares of tax payments. The establishment of CFC tax system is not just for fiscal revenues, but also for the improvement of tax fairness—the latter being more important. Finally, this study concludes with suggestions that may be the useful references for the government to design CFC tax system in the future. Key words：Controlled Foreign Corporation, Tax Haven, Multinational Enterprise