This thesis is focused on the assessment of the legal, tax and accounting aspects of the tax optimization and using of tax havens. There were chosen the following tax havens: the Netherlands, Cyprus, Malta, Belize, the Seychelles. The choice of these states was based on statistics made by the company Bisnode (2015). In these states there were compared legal conditions and costs connected with establishing of company, tax aspects which were focused on the corporate income tax (with and without existence of the permanent establishment) and accounting aspects. Because of the better illustration of these aspects there was made a case study. This study was focused on the fictive small Czech entrepreneur who wanted to reduce the costs through using of tax havens. Tax havens and also the Czech Republic were compared in each chosen aspect. At the end there was determined a final order of selected states (each aspect had the same value on the final order). For the comparison there was used a scoring method (exactly in comparison of legal and accounting aspects). Tax aspects were evaluated according to the amount of tax duty. The final order was based on arithmetic mean of partial orders. It was found out that the best country for our small entrepreneur is the Czech Republic (with and also without establishing of permanent establishment). However, this result is affected by the chosen aspects and also by the size and main aim (reduce costs) of the entrepreneur. So we can´t say that these tax havens are disadvantageous for everyone all the time.

La transposition de la 3ème directive européenne de 2005 sur la lutte contre le blanchiment d'argent dans notre droit français est effective depuis l'ordonnance de 2009 relative à la prévention de l'utilisation du système financier aux fins de blanchiment de capitaux et de financement du terrorisme. Il s'agit d'un texte fondamental pour tout professionnel assujetti au dispositif de la lutte anti-blanchiment. L'introduction de la.notion de proportionnalité dans les obligations de vigilance confère une réelle souplesse au régime de contrôle des transactions. Ce passage d'un contrôle rigide à un contrôle reposant sur le risque présenté par l'opération peut toutefois susciter quelques inquiétudes. Cette «approche risque» n'est-elle pas dangereuse de par les dérives auxquelles elle peut conduire ? Le nouveau dispositif imposant des obligations modulables en fonction du risque de blanchiment s'avère-t-il plus satisfaisant au plan théorique ? Plus efficace en pratique ? Est-il compatible avec les autres obligations auxquelles sont tenues les professionnels, acteurs de la lutte contre le blanchiment ? De plus, dans quelle mesure la transposition de la directive européenne retenue par le droit pénal français était la seule transposition possible ou, à tout le moins, la plus pertinente ? La véritable solution n'est-elle pas l'adoption d'une incrimination internationale de blanchiment ? En d'autres termes, il ne s'agirait pas seulement d'harmoniser les législations européennes et même internationales mais d'unifier ces législations et de créer une infraction de droit international pénal, infraction assortie de règles procédurales spécifiques / The transposition of the 3rd European directive published in 2005 dealing with anti-money laundering in French law bas taken effect since the 2009 order on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing. It is a fundamental text for any professional subject to the anti-money laundering plan of action. The introduction of the notion of proportionality in the duty of care conf ers a real flexibility on the transactions control regime. This transition from an inflexible control to a new control based on the risk presented by the operation may however raise concems. Is this "risk approach" not hazardous according to excesses it might lead to? Do the new measures imposing adjustable obligations depending on the risk of laundering prove to be more satisfactory theoretically speaking? Are they more effective in practice? Are they compatible with the other obligations the professionals - actors of the fight against money laundering - are required to comply with? Moreover, to what extent was the transposition of the European directive retained by the French criminal law the only possible transposition or, at least, the most relevant. Is the real solution not to be found in the adoption of an international money laundering incrimination? ln other words, it is not just a question of standardizing European and even international legislations but also of unifying these legislations and creating a new criminal offence in the intemational criminal law, an offence accompanied by specific procedural regulations.

The main objective of this Master's thesis is to analyze the regulation of tax liability of legal person and on the basis of the analysis to reveal opportunities for optimization of the tax liability by means of practical examples of the application of tax optimization. To achieve this objective, the work is divided into five main chapters. The purpose of the first four chapters is to provide a sufficient theoretical base connected with tax optimization. This section begins with the interpretation of general problems of the theory of corporate taxes, which gradually passes into the interpretation of more specific areas. In the following part of the work the selected methods of tax optimization are used on illustrative numerical examples, the conditions for the application of optimization methods are determined and the situation before using the optimization and after the use is compared. The conclusion summarizes the possible ways of reducing the tax burden of the firm and the possibility of their practical use.

The aim of this thesis is to provide a description of the phenomenon of tax havens in relation to the Czech Republic. The thesis begins with description of theoretical background of this topic including the description of main sectors used for international tax optimalization. Among the areas of the optimization methods, which are described in this thesis, belongs dividends, royalty payments, interest income. The thesis presents an impact of tax haven existence to Czech economy. The impact on public budget is shown and counted on the model example of fictive international company. As a reaction of losses caused by profit shifting to more favourable jurisdictions international organizations are coming up with initiatives to reduce the possibilities of tax planning. The thesis is concluded with an overview which Czech republic should accept to reduce profit shifting to other jurisdictions.

The aim of this thesis is to outline the optimization of taxes on corporate income and its use in practice. The first part defines the basic concepts and highlights the issue of the link between accounting and tax rules. The following is a detailed description of the transformation of the accounting profit to the tax base with a number of example and accounting schemes. The second part focuses on explaining the concepts of tax savings and tax avoidance.They are described main methods of illegal tax evasion and how to fight against them at the national level and the European Union. In addition, this part characterizes the basic concepts of tax havens, their benefits and efforts to reduce them. The conclusion is given virtually complete practical expample using the methodology described in this work.

Corruption, Tax Abuse, and Financial Secrecy PhD Dissertation, Miroslav Palanský, IES CUNI, 2020 Abstract This dissertation is composed of three papers that focus on different aspects of the relationship between the public sector and individuals who do not comply with the norms and regulations set by the government. I classify the ways in which individuals do so into two categories - corruption and tax abuse. Corruption, defined as the abuse of entrusted power for private gain, results in individuals obtaining more benefits from the public sector than is intended. Tax abuse, on the other hand, is defined as contributing less to the public sector than is intended. The last chapter of the dissertation focuses on financial secrecy, which I argue is the key facilitator of the two channels. In Chapter 2, I show that companies that donate money to Czech political parties subsequently report abnormally high profits, pointing to preferential treatment that these firms enjoy as a result of their political connections: I conservatively estimate that the connected firms outperform their non-connected but otherwise similar competitors by 8 to 12% following the establishment of the connection, which is a higher effect than found previously for more developed economies. Importantly, however, I find that the effect...

Magister Legum - LLM

This paper describes and analyzes the configuration, the normative regulation and assumptions of tax avoidance and its differentiation from tax evasion, current regulations on matters related to tax avoidance, disputes relating to this figure due supported, the impact of international tax avoidance through tax havens figure, the way our country aims to combat this figure and finally propose suggestions for improving the anti-elusive regulations in order not to infringe against the taxpayer and any proper legal regulation. / En el presente ensayo se exponen y analizan la configuración, la regulación normativa y los supuestos de la elusión tributaria, así como su diferenciación con la evasión tributaria, la normatividad actual sobre materias vinculadas a la elusión tributaria, las controversias en relación a esta figura debidamente sustentadas, el impacto de la elusión tributaria a nivel internacional a través de la figura de los paraísos fiscales, la manera cómo nuestro país pretende combatir esta figura y, finalmente, planteamos propuestas de mejora a la normatividad anti-elusiva a fin que no se atente contra el contribuyente y exista una adecuada regulación jurídica.

The exchange of tax information has received ample attention recently, due to a number of recent headlines on aggressive tax planning and tax evasion. Whilst both participating tax authorities will gain when foreign investments (FDI) are bilateral, we demonstrate that FDI receiving nations will lose in asymmetric situations. We solve a bargaining model that proves that tax information exchange will only happen voluntarily with compensation for this loss. We then present empirical evidence in a global panel and find that a tax information exchange agreement (TIEA) or a double tax treaty with information exchange (DTT) is more likely when the capital importer is compensated through official development assistence (ODA). We finally demonstrate how the foreign account tax compliance act (FATCA) and similar international initiatives bias the bargaining outcome in favour of capital exporting countries. (authors' abstract) / Series: WU International Taxation Research Paper Series

The role of tax havens in the global issue of tax evasion has been illustrated by numerous studies. In 2009, a major international initiative has been launched by G20 and OECD with a purpose to put an end to offshore tax evasion. Yet the outcomes of this tax haven crackdown are often contested. This thesis brings new findings to the empirical research that has been done on the field of crackdown's evaluation. First, I confirm the results of earlier academic papers and I find a negative impact of information exchange treaties on the value of funds placed in tax havens. Second, I extend the existing research shifting the attention to deposits in non-havens, concluding that also the money from tax havens placed on non-havens' bank accounts disappear after signing a treaty. In the final part of the thesis, I - for the first time in literature - link the data on cross-border deposits with a measure of financial secrecy. I find that a decrease in secrecy score corresponds to a decline in deposits on a sample of all countries and non-havens. All my findings suggest that weakening the financial secrecy is associated with a significant outflow of cross-border deposits.