Šiame darbe per mokestinių pajamų lygio ir struktūros, valstybės išlaidų lygio ir struktūros, valstybės skolos ir tiesioginių užsienio investicijų kaitos prizmę nagrinėjamas tarptautinės mokestinės konkurencijos poveikis Lietuvos valstybės finansų sistemai ir ūkiui. Darbe pristatomi pagrindiniai tarptautinės mokestinės konkurencijos aspektai, išskiriant du vyraujančius požiūrius į šį reiškinį. Holistinis požiūris pateikia neigiamas nuostatas mokestinės konkurencijos atžvilgiu, metodinio individualizmo požiūris į mokestinę konkurenciją yra teigiamas. Darbe suformuluotos prielaidos apie tarptautinės mokestinės konkurencijos ir mokestinės naštos, mokestinių pajamų ir išlaidų struktūros, valstybės skolos, tiesioginių užsienio investicijų pokyčių ryšį Lietuvoje per 1993 – 2008 m. laikotarpį. Atlikto tyrimo rezultatai rodo, kad Lietuvoje tarptautinė mokestinė konkurencija turėjo daugiau teigiamų efektų nei neigiamų. / This diploma paper analyses impact of international tax competition to Lithuania‘s public finance sector and economy trough tax revenue level and structure, public expenditures level and structure, public debt and foreign direct investments change trends. This paper introduces main theoretical international tax competition issues, separating two dominant views to this phenomenon. Holistic view proposes negative altitude to tax competition, methodical individualism has positive view to tax competition. In order to achieve main paper‘s goal hypothesis about international tax competition and tax burden, tax revenue, expenditure structure, public debt, foreign direct investment connection in Lithuania during period of year 1993 – 2008 are held. Research results shows that in case of Lithuania international tax competition had more positive effects than negative.

Syftet med uppsatsen är att analysera ändamålsenligheten med de svenska CFC-reglerna samt att problematisera det nuvarande CFC-regelverket utifrån de åtgärder och nyckel-överväganden som lyfts fram ur OECDs två rapporter om BEPS. BEPS är ett omfattande problem, vilket har presenterats i två rapporter framförda av OECD. Syftet med rapporterna är att de ska mynna ut i åtgärder på det mellanstatliga beskattningsområdet för att motverka BEPS. Många länder har inkorporerat CFC-regler i sina skattesystem. Några av de åtgärder som presenteras i rapporterna avser att förbättra just dessa regler. För att kunna tyda dessa åtgärder har nyckelöverväganden från OECD lyfts fram. Dessa är; ökad transparens och utbyte av information, heltäckande åtgärder och nytänkande samt gemensam ansats och samspel mellan regler. De flesta länder har vissa grundkomponenter gemensamt när det kommer till strukturen av deras CFC-regler. Dessa gäller bl.a. definitionen av ett CFC-bolag, vad för slags infly-tande eller kontroll det ska finnas mellan det inhemska bolaget och CFC-bolaget, vad som utgör låg beskattning samt vilken typ av inkomst som är hänförlig till ett CFC-bolag. I Sverige återfinns CFC-reglerna i 39a kap. IL. De svenska CFC-reglerna är ändamålsenliga såtillvida att deras strukturella utformning ger dem ett brett tillämpningsområde. Däremot kan reglerna kritiseras för att vara oupp-daterade på två punkter. Samspelet mellan skatterättsliga regelverk, dels inhemska och dels mellanstatliga, är nyckeln till att lösa BEPS. En uppdatering av det svenska CFC-regelverkets ändamålsenlighet kan därför vara en liten pusselbit i det komplexa BEPS-pusslet. / The purpose of this thesis is to analyse the effectiveness of the Swedish CFC rules and to problematize the current CFC rules against the actions and key considerations highlighted by the OECD's two reports on BEPS. BEPS is a widespread problem, which has been presented in two reports carried out by the OECD. The purpose of these reports is to lead to actions in the cross-border taxation area that are aimed at counteracting BEPS. Many countries have incorporated CFC rules into their tax systems. Some of the actions presented in the reports are designed to improve these rules. To be able to interpret these actions, some key considerations have therefore been highlighted. These are; increased transparency and exchange of information, comprehensive actions and innovative thinking and common approach and coherent rules. Most countries have some basic elements in common, when it comes to the structure of their CFC rules. These relate inter alia to the definition of a CFC, what kind of influence or control there should be between the resident company and the CFC company, what constitutes low taxation and what type of income that is attributable to a CFC company. In Sweden, the CFC rules are found in the 39a Ch. IL. The Swedish CFC rules are effective in the sense that their structural design gives them a wide scope. However, the rules can be criticised on two grounds for being outdated. The interaction between tax regimes, partly domestic and partly cross-border, is the key to solve BEPS. An update of the Swedish CFC rules’ effectiveness may therefore be a small piece in the complex BEPS puzzle.

One way a multinational corporation can further satisfy its primary objective, which is to maximize shareholder wealth, is to minimize the share of its income that is transferred through taxation to the various sovereign nations within which it does business. The profit maximizing firm attempts to maximize (minimize) taxable income in those jurisdictions where income tax burdens are the least (most) in such a way as to diminish the present value of its global total tax burden. While the US corporate income tax rate has remained relatively stable over the decades since most US income tax rates were last slashed as part of the Tax Reform Act of 1986, across the rest of the world, non-US corporate income tax rates have continued to fall. Even though the US statutory rate was among the lowest corporate income tax rates of any industrialized nation in 1988, by 2008, due to continuing rate decreases around the globe the US rate had become one of the highest corporate income tax rates amongst the G-8. In April of 2012, the US statutory rate as applied to corporate income became the highest among all the Organization for Cooperation and Economic Development (OECD) countries. This study will examine the behavior of option intensive corporations during the late 1990's. Coinciding with the longest recorded economic expansion in the history of the United States and coupled with the so-called "internet bubble" during the second half of the decade, this period of rapid stock price appreciation was also a time when many highly profitable companies faced substantially lower current US tax liabilities due to the large tax deductions resulting from the employee exercise of increasing quantities of non-qualified stock options at substantial gains. Enormous tax losses reported by employee stock option granting firms were sufficient to eliminate not only current US corporate income tax liabilities but also several years of future tax liabilities for some firms. Previous research has documented an increasing proportion of US multinational corporate income recognized in foreign jurisdictions, thereby escaping the relatively high US corporate tax rates until the foreign profits are repatriated back into the US. Perhaps US corporate income tax rates are so high in comparison to equally suitable substitute foreign locations that many firms have relocated their income producing activities to lower taxed jurisdictions abroad. Or it may be that US multinational firms engage in various cross border income shifting techniques to avoid high US corporate income tax rates and reduce their overall global tax burden. Profitable option intensive firms in the late 1990's faced in effect lower US corporate income tax rates due to their extensive employee stock option deductions and resulting net operating loss carry-forwards. It is possible that these firms had more incentive to recognize income domestically than their non-option intensive corporate peers. Using a sample of the largest US firms comprising the NASDAQ-100 index on May 31, 2001, this study found evidence of higher US profitability among NASDAQ-100 multinational firms with the largest deductions resulting from the exercise of options by their employees during the 1997 - 2000 fiscal years suggesting that these firms where more likely to recognize or even generate income within US borders when facing effectively lower US corporate income tax rates. Such an observation has potential public policy implications and contributes to the literature on tax motivated income shifting behavior.

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.

The theme of this thesis is focused on international tax planning with a narrower specification using offshore companies and all on the field of investment banking. The task of this thesis certainly does not an accurate tax analysis of individual taxes paid standardly in the classic onshore countries. On the contrary, the intention is to provide a wider range of options which the international tax planning can offer to us and what are the specifics of individual, for us certainly attractive, countries or in which cases we should already start to think to optimizing the tax in the international context. I will use Czech-Slovak investment J & T group to analysis mentioned above.

This work analyses tax-favored areas which are used in international tax planning. The first part of this work contains information about corporate tax in the Czech Republic and characterizes tax havens in general. The second part presents tree states -- The Bahamas, Cyprus and Great Britain and describes an establishment of model society in these countries. The cost of setting up a company and taxation are compared with a fictive limited company which is based in the Czech Republic. In the conclusion, there are some additional information - for instance arrangements against tax havens, tax havens of the world and czech firms in tax havens.

In October 2021, 137 countries and jurisdictions agreed on a common approach towards a global minimum tax of 15% on the profits of large multinational companies that is referred to as the Pillar Two Model Rules, ‘Anti Global Base Erosion’, or ‘GloBE’ Rules. This political agreement implies that member countries who wish to implement such a tax regime have to streamline its design by modelling it after the so called Global Anti-Base Erosion Proposal (‘GloBE’) that the IF has developed as ‘Pillar 2’ of its work program on tax challenges arising from the digitalization of the economy. On 17 June 2015, the European Commission presented an Action Plan for a fairer and more efficient corporate tax system in the European Union (EU). The powerful document re-defines the future course of corporate taxation in the EU. The GloBE Model Rules are an opportunity – an impulse – for the European Union to begin coordinating tax rates in corporate income tax among its Member States and to proceed further, in the near future, in the direction of harmonizing those rates. On December 22, 2021, the European Union (EU) announced the Proposal for a Directive to ensure a global minimum level of taxes for multinational groups. It follows the Pillar Two implementation planoutlined in the Inclusive Framework (IF) statement released on October 8, 2021, and the model rules published on December 20, 2021.5In this thesis the authors focus on whether the Global Anti-Base Erosion (‘GloBE’) rules, specifically Income Inclusion Rule, as set out in an Organisation for Economic Co-Operation and Development (‘OECD’) Blueprint of October 2020, comply with the EU fundamental freedoms. This compatibility is tested based on two differentscenario’s. In the first scenario the assumption is taken that the GloBErules will be implemented directly by the Members States (Assumption A). It will be addressed by the rule of reason doctrine by analysing which freedoms are getting affected then making a restriction test, then justification test and finally the proportionality test. In the second assumption is that the GloBE-rules will be implemented indirectly through an EU Directive (Assumption B). This analysis will show that, even though the GloBE-rules conflict with the freedom of establishment, they could still be implemented effectively because of the considerable discretion granted to the Union legislature by the Court of Justice of the European Union (CJEU).7 The directive at discussion in the thesis is the Minimum tax directive 2022/2523.

The thesis is focused mainly on changes in the field of tax planning, global exchange of information and documents, on the basis of which the information exchange is realized. The thesis is also devoted to protection of identity of owners of assets and income, and various instruments which allows preserving it. The practical part of the thesis is formed by a case study. The aim of the thesis is to coherently examine and summarize the changes that took place in international tax planning over the past few years, mainly because of increased international cooperation in tax matters.

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Issues of international tax relations are a very important matter in the domain of international business. Double taxation of income and capital, administrative demands of crossborder tax relations, and from the point of view of tax authorities also fight against tax evasion, these all are problems that must be considered rigorously in a world economicaly based on international exchange of goods and services. What's more, these issues are dealt with on mutualy distinct legal legal levels of domestic, European and international law, and only with deep analysis of all three systems in context of each other can be identified what rules govern specific issues of international tax relations. Although some areas, especially avoding international double taxation, are nowadays resolved in a satisfactory way, other issues, e.g. crossborder assistance in collection of taxes, are yet to be settled complacently. This thesis is aimed at exploring international tax relations and legal rules, that govern these relations. Where possible, author takes broader look at issues at hand; where finding relevant resources is too challenging, it takes a point of view from perspective of czech legal system including valid international agreements. Main part of this text deals with issues related to prevention of...