Prior to the last reform of the transfer pricing regime, only the application of specific valuation methods was allowed, which generated several practical and constitutional problematic issues. These were partially solved with the recent inclusion of a provision that allows the application of “other methods”. This paper analyzes the issues of the previous situation, as well as the solutions presented by the reform and its corresponding limits. Finally, the authors propose several precisions that, in their opinion, should be included in the regulation of the “other methods”. / Previamente a la última reforma del régimen peruano de precios de transferencia, solo se permitía la aplicación de métodos específicos de valoración, lo que generó una serie de problemas de índole práctica y constitucional. Estos se resolvieron parcialmente con la reciente inclusión de una disposición que permite la aplicación de “otros métodos”. El presente trabajo analiza la problemática de la situación previa, así como las soluciones que presenta la reforma y sus límites. Por último, se propone una serie de precisiones que, a juicio de los autores, deberían incluirse en la reglamentación de los “otros métodos”.

The diploma thesis is focused on comparison of company tax in Czech Republic, Austria and Germany. It is deeply focused on corporate income tax of the legal entity and its construction parts. The aim of the work is to acquaint the reader with differences during setting the tax amount at mentioned countries and evaluate tax competition between countries as mentioned above. First part of this thesis is focused on basic concepts and introduction of statutory income tax treatment in the Czech Republic, Austria and Germany. Next section of this thesis is focused on comparing elements of the corporation tax with highlighting country differences and calculation of the income tax at a sample company.

1 Abstract To study the effect a change in a tax base has on the corresponding tax revenue is a useful tool to better predict future tax revenues. This property is called a tax revenue elasticity but generally it does not get as much attention as it deserves, and when it does, key points like using data adjusted for the effects of tax reforms or distinguishing between the short-run (instantaneous) and the long-run (equilibrium) elasticity are often omitted. In my thesis, I am the first one to estimate the tax revenue elasticities for Slovakia. I use a unique dataset adjusted for the effects of tax reforms and tax changes to estimate both the short-run and the long-run elasticities for the three tax categories th at account for the majority of each year's tax revenue - Personal Income Tax, Corporate Income Tax and Value Added Tax. I obtain a long-run elasticity of 0.98, 1.28 and 0.94 for the Personal Income Tax, the Corporate Income Tax and the Value Added Tax respectively and a short-run elasticity of 3.51 and 1.93 for the Corporate Income Tax and the Value Added Tax respectively. I do not obtain a significant estimate in the case of the Personal Income Tax. Additionally, I find that it takes more than a year for the elasticity to reach its equilibrium value for all the three tax categories and that there...

This diploma thesis deals with tax optimization of companies. The thesis is divided into two main parts - the theoretical and practical part. The introduction of the theoretical part describes the history of taxes, their basic characteristics and the importance of their collection for today's society. Subsequently, the tax system of the Czech Republic with a focus on value added tax and corporation tax is presented. The practical part deals with specific possibilities of optimization of the amount of corporate income tax and value added tax. The opening chapter of the practical part emphasizes the difference between tax optimization and tax evasion. Subsequently, the options for optimizing the income tax are presented - from the very start of business, through the optimization of the tax base, tax deductions and deductible items. In the case of value added tax, the work deals on one hand with the tax registration itself and on the other with the group tax registration. Work should provide comprehensive guidance for reducing tax burden on businesses.

This thesis introduces the tax system of the Czech Republic. The corporate income tax in particular is specified in bigger detail. Its basic structural elements are described with the focus on the transformation of the accountable profit to the tax base. The practical part is divided into chapters, each of which deals with the optimization of the amount of the real tax liability. The content, instruments mentioned and methods for decreasing company tax liability applied suggest this work more likely addresses smaller and medium-sized companies. These companies need what is referred to as tax planning. This thesis analyzes the possibilities of the use of tax-deductible items provided by law, tax abatements; further it specifies cost and revenue conception of tax optimalization or more precisely the amount of the accountable profit or tax base. The aim of the practical part is to identify tax optimization possibilities and to compare on concrete cases what tax saving or other advantages to the taxpayer each method brings.

本文利用台灣2010年降低營利事業所得稅稅率之改革，檢驗公司稅率對受雇員薪資之影響。與過去文獻不同之處為，本文考量稅率與公司決策互相影響而產生內生性，因此以工具變數進行兩階段最小平方法以避免產生偏誤。並以綜合所得稅與營利事業所得稅資料對全體受雇員之個體進行分析，而非僅針對上市櫃之公司。最後發現有效稅率下降1% 能提升台灣整體受雇員平均 0.16% 的薪資。而考量個體異質性下，進行次組分析，發現在技術密集產業、大型公司、公司頂層員工所受到的影響較大；而其他產業，中小型公司以及公司基層員工的薪資受到稅率的影響較小，使得政府稅改政策並不如預期提升全民薪資。 / This paper estimates the effect of corporate income tax rate on wage by using the Taiwan Corporate Income Tax Reform of the year 2010 as a natural experiment. Different from the previous literature, we consider the endogenous relationship between the tax rate and the policy of the company. Thus, the two stage least squares method is used to overcome the endogeneity bias. Additionally, our participants include all the individual employees from the data of Individual Income Tax and Corporate Income Tax rather than only the employees of listed company. Our results indicate that a drop of 1% in corporate income tax rate would increase the wage by 0.16%. Furthermore, we test for the heterogeneous firm and worker effects by using subgroup analysis and find the technology-intensive industries, the large companies and the high-classed employees within firm have a greater impact. On the other hand, the non-technology-intensive industries, the small and medium company and the low-classed employees within firms have a smaller impact. Therefore, the Tax Reform didn’t increase the overall wage as expected.

The aim of this thesis is to analyze what was the influence of corporate tax rate and total paid amount on corporate income tax on GDP and unemployment in the Czech Republic. The essay also describes the impact of European subsidies given to Czech corporates as primary receivers on GDP and unemployment in the Czech Republic. A comparison of these two macroeconomic factors is provided. Conclusions show that there are some impacts which are not supposed to be transferred to a concrete comparable numbers. The thesis provides detailed overview of main impact of derivation of European subsidies given to Czech companies as primary receivers and changing corporate income tax on GDP and unemployment. The comparison of above influences is provided both on theoretical basis and the real one in the period of 1993-2013 for the Czech Republic. Conclusions and author's ideas are supported by professional publications. The thesis provides information on how the problematic is width and deep within these impacts. Any reader can create his/her own opinion on the problematic based on provided information and data.

This thesis analyzes an impact of a company size to its effective tax rate. Back looking microeconomics principle is used for the analysis. A dependence of the effective tax rate and company size measured by the employee headcount is verified for the segment NACE 23 in the Czech Republic for the period 2003 -- 2012 in the thesis. The dependency is proved by a negative correlation between the effective tax rate and the company size. The thesis contains also the analysis of historical development of relevant sections of the Czech Income Taxes Act. An impact of particular items adjusting accounting profit or loss to the tax base is analyzed through an alternation coefficient. The alternation coefficient is calculated on the accounting/tax items of the particular company operating in segment NACE 23.

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 diploma thesis is aimed at analysis of corporate income tax, often discussed part of a tax system, which has lately been also subject of a tax competition. The primary objective of this work is analysis of collection of corporate income tax in the Czech Republic, according to taxpayers, and different economic sectors NACE. The secondary objective is analysis of tax deduction, especially donations, spending on research and development, and tax credit. The applied methods are analysis, comparison; out of the mathematical and statistical methods regression analysis is used. The analysis is done on years from 2005 to 2013.