The thesis analyzes the role of Panama in international trade. The first chapter is dedicated to basic information about Panama. It describes its history and briefly describes the specifics of Panama's market. The second chapter discusses the business environment, its general characteristics. Its main ingredient is a special tax regime, because of which Panama is considered as a tax haven. It analyzes the economic situation in Panama and it is dedicated more to two major pillars of the economy of Panama, the Panama Canal and the Colon free zone. It focuses on potential investment opportunities in Panama, which are stimulated by tax incentives. Characteristic of the social environment focuses on the facilities of Panama's population as workforce and education level in the country. It describes the evolution of culture and Panama is characterized by its cultural peculiarities of the universal cultural dimensions of Hofstede. Also describes specifics relating to business dealings and activities associated with it. The technological environment draws attention to the technological amenities of the country, the government organizations that are specialized to promote its activities in this area. The third chapter deals with foreign trade of Panama. It describes the national strategy designed for the years 2004 to 2009, government institutions supporting the Panamanian foreign trade and agreements that Panama has signed for development of foreign trade. It also discusses evolution foreign trade indicators in 2008. The last chapter focuses on trade cooperation between Panama and the Czech Republic.

The thesis defines legal status of Liechtenstein in the European Economic Area. It is divided into three consecutive chapters. The first chapter consists of two parts - general and economic characteristics of Liechtenstein. The general characteristic is based on the author's experience supported by scientific literature, while economic subchapter is based largely on statistical data. The second chapter focuses on the legal status of Liechtenstein and its position on international scene. The position is viewed from two perspectives, which affects it the most. First, from the perspective of participation in selected international organizations and second, the influence of close relationship with Switzerland. The last chapter analyses international litigation to which Liechtenstein is a party. The aim of this thesis is to define the legal relations of Liechtenstein, which forms its position, using the methods of analysis.

租稅天堂係一相對的概念，故其定義則因國而異。在企業國際化之後，租稅天堂的運用日趨頻繁，而方式則不一而足。其操作的原則不外乎透過移轉計價，即收入與費用的調整，將集團的利潤儘量集中在租稅天堂基地公司，以享受租稅遞延─甚至透過第二次隱藏的措施以圖謀中期或長期遞延利益。 　　我國自民國七十六年放寬外匯管制、七十八年放寬投資範圍及財務標準以來，對外投資的金額與件數激增。為瞭解我國廠商之成立控股公司與從事移轉計價之行為，乃就對外投資事業進行因素分析與Logit模型的檢定，分別尋求兩者行為的共同因素及具有影響力的動機。 　　雖然根據迴歸的結果顯示，企業乃是基於許多商業上的理由而使用租稅天堂；然而，其正當性的前提為所有的交易必須是純粹基於商業上的理由而非人為的策略。故從稅務機關的立場而言，它也有理由來關心交易是否按常規的價格或者利潤是否被不當地移轉。所以，合理的稅制乃必須兼顧廠商的商務上的需要與政府維持稅制公平、中立的職責。 　　惟觀乎我國目前對涉外交易之租稅規定，似較偏向於對外來投資之獎勵及規範，對於我國企業對外投資之相關稅負問題則規定甚少。緣此，本文乃就各國對於反租稅天堂措施中常用的一般性與特別性的立法規定，作一比較性的歸納，然後針對美國1993年的修正案作一說明。最後，對於假華僑案與重複課稅之減緩予以檢討，期能從中尋求出一個較為完善的稅制。

Offshore jurisdictions have become popular among corporations around the globe. They provide opportunities to reduce taxes by registering companies there. The Russian large firms have joined the trend, but exploit offshore schemes in different ways. They incorporate offshore companies with their subsidiaries operating in Russia. The main purpose is to protect assets from hostile capture by other businesses or even the government. Thus, businessmen stay hidden as end beneficiaries behind the offshore companies’ chain. The offshorization in the country has its enormous scale. Up to 90% of the largest companies are involved in offshore patterns. The government makes some efforts to force companies to come back to the country, but they are not effective. To succeed, corporations should experience the improved business climate and have an opportunity to defend themselves in fair courts. It is the government’s responsibility to make such appealing conditions. As a result, nowadays, Russia suffers not only from less tax collection, but also from losing control over strategically important enterprises and even industries. Thus, the phenomenon threatens to the country's national security.

The result of the global integration of the world economy are globally operating corporations. Multinational enterprises operate in different countries whose economic policies are different from each other. These differences have considerable impact on tax policy. Taxes are the subject of conflicting interests of the international business and tax policy. One of the current objectives of the MNEs is to reduce the total cost in order to achieving competitive advantage in the global market as well as to minimize the global tax liability through its optimization. To achieve these objectives the international tax planning is a widely used means. International tax planning uses tax havens and their favourable tax conditions to divert profits. Minimizing tax liability often leads to tax avoidance or tax evasion. Different legislative adjustments and mutual meeting of local and international legislation gradually uncover gaps and weaknesses enabling reduction and shedding of profits. Consequently, states are deprived of significant tax revenue. One of the most common and most important methods to minimize the tax liability of MNEs is transfer pricing. Transfer prices are to be determined in accordance with the arm's length principle, using comparative analysis and an appropriate method of assessment. Transactions carried out between associated enterprises may be regarded as a risk area which gets to the fore states and tax administrations. The first part of thesis focuses on tax policy in terms of international taxation of income and international tax planning. The second part presents a transfer pricing. The third and last part describes the practices of MNEs in transfer pricing and corresponding initiatives of national and international organizations.