The master’s thesis focuses on determining of methodology for calculating of tax base in the service permanent establishment of Slovak tax resident in the Czech republic. Based on analysis of Czech accounting, tax regulations and OECD model agreement, data are used to determine the methodological manul and its subsequent application.

This diploma thesis deals with the obligations for implementing the construction project in the Slovakia and its taxation. At first is defined basic terminology, concept of single market of the European Union and the harmonization process of direct and indirect taxation. In the analytical part of the thesis are relevant sources of international, union and national law analyzed. The practical part is focused on specification construction contract, accomplishment all obligations and an exemplary taxpayer's tax liability is calculated.

This master´s thesis concerns optimalization of company taxation. The aim is, through analysis of the company KHF GROUP, s.r.o., suggest steps to optimalization of taxation.

La mondialisation de l’économie, le développement des moyens de transport et de communication et l’émergence des paradis fiscaux rendent la connaissance de la fiscalité d’autres pays indispensable, tant par le fiscaliste praticien que par le chercheur.La France et la Belgique ont une communauté de langue et de culture en plus de la proximité géographique. Connaître sa fiscalité et la comparer à la fiscalité française est utile à tout fiscaliste qui pourra alors se faire sa propre idée sur le statut de paradis fiscal qu’on lui attribue. Nous avons choisi de comparer l’imposition des revenus étrangers car, ceux qui changent de pays pour éviter la pression fiscale, sont souvent des personnes ayant une forte activité internationale. En l’absence de convention préventive de double imposition, l’imposition de tels revenus est plus favorable en France, quand ils sont encaissés par des personnes morales. En revanche, lorsqu’ils sont encaissés par des personnes physiques, l’imposition est plus avantageuse en Belgique.Mais les deux pays ont conclu beaucoup de conventions préventives de double imposition de sorte qu’il est difficile de trouver un pays qui ne leur est pas lié par une convention fiscale. Or, il s’avère que la Belgique, à travers ses conventions, adopte des mesures fiscales nettement plus favorables que la France et ce, afin de favoriser l’expansion économique de ses résidents et attirer aussi des capitaux étrangers.A cette situation, s’ajoute le fait que ce pays autorise des montages fiscaux qui seraient sanctionnés en France sous l’angle de l’abus de droit.On comprend alors pourquoi certains hommes d’affaires n’hésitent pas à s’y domicilier. / According to several factors such as the economy globalization, the development of transportation and communication supplies and the rising of tax heavens, tax lawyers have to reach a high expertise and knowledge of foreign tax systems.Belgium and France share common roots of language and culture in addition to the geographical proximity. To be especially aware of the Belgium tax law scheme is absolutely necessary for every tax lawyer in particular in a view to compare and have an opinion about the heaven nature of the Belgian system.As far as it is impossible to compare every point of the two systems, we decided to focus only on the taxation of foreign income, because of the international activity of the taxpayers willing to lower the tax pressure. Without an international tax treaty, foreign incomes are less taxed in France when they are received by a company but the situation is different when the receiver is a person. However it has to be noticed that Belgium and France have developed a huge international tax treaty network. The Belgium one is analyzed as being more attractive for foreign investments and national economic expansion. Besides, Belgium has a tax system which authorizes tax schemes seen sometimes as an abuse of right in France. As a consequence the exile of business men can be understood.

Taxation of permanent establishments is one of the most complicated areas within international tax law. The system of permanent establishment is based not only on the national legislations of relevant states, but also (mainly) on the international double taxation treaties. This diploma thesis analyses those issues in the taxation of permanent establishments, which are the most up-to-date or can be considered as the key questions of the whole concept and therefore can be significant for the future development of the permanent establishments. However the technically perfect system of permanent establishments should come hand in hand with the practical feasibility and overall efficiency. This assumption is nowadays challenged by several trends like the growing popularity of offshore tax heavens or the development of information technologies, which complicate the determination of (fixed) place of business through which the business of an enterprise is wholy or partly carried on. The technical analyses in this thesis are, therefore, supplemented by the objective evaluations from the perspective of valid legislation, possible approaches of the tax authorities, as well as of the enterprise considerations and also the global international taxation picture. This involves also the aspects of tax policies at the level of sovereign states, especially the Czech Republic.

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In support of a short dissertation entitled - "A critical review of the source and residence principles of taxation of income : A place for both principles in the South African tax system?" Qbjeetives To review and critically examine the application of the source and reside.nce principles regarding the taxption of income in South Africa, and to reveal the extent of the existence and application of a hybrid tax system in respect of the source and residence principles. To examine the legal principles and policy considerations arising from the existence of a hybrid tax system, inter alia, in the context of the Fifth Interim Report of the Katz Commission and consequent legislative developments. with a view to recommending. where appropriate, tax reform. Methodology iDd AQProach A review of relevant authority,liter@ture, principles and legislation. Conclusion To draw conclusions and recommendations regarding the merits of adopting a hybrid system in South Africa and, where appropriate, recommend legislative reforms particularly with regard to business income. / Mercantile Law / LL.M. (Mercantile Law)

In support of a short dissertation entitled - "A critical review of the source and residence principles of taxation of income : A place for both principles in the South African tax system?" Qbjeetives To review and critically examine the application of the source and reside.nce principles regarding the taxption of income in South Africa, and to reveal the extent of the existence and application of a hybrid tax system in respect of the source and residence principles. To examine the legal principles and policy considerations arising from the existence of a hybrid tax system, inter alia, in the context of the Fifth Interim Report of the Katz Commission and consequent legislative developments. with a view to recommending. where appropriate, tax reform. Methodology iDd AQProach A review of relevant authority,liter@ture, principles and legislation. Conclusion To draw conclusions and recommendations regarding the merits of adopting a hybrid system in South Africa and, where appropriate, recommend legislative reforms particularly with regard to business income. / Mercantile Law / LL.M. (Mercantile Law)

The present diploma thesis is focused on the definition of differences resulting from the comparison of two chosen forms of doing business of a foreign person in the Czech Republic. It specifies differences from the viewpoint of the commercial law and the obligations as an accounting unit. Foremost, the thesis includes a detailed analysis from a tax point of view. The thesis involves a model example to define the precise amount of tax obligation incumbent on the both forms of business of a foreign person in the Czech Republic. This model example constitutes a basis for the final evaluation and to draw relevant conclusions. Suggestions and recommendations mentioned in this work can serve as an overview of the approach to the taxation of cross-border income and at the same time as a tool for the elimination of errors and discrepancies in connection with the chosen form of business of a foreign person in the Czech Republic.