This thesis puts brain to possibilities offered to companies with domicile in the Czech Republic via international tax planning, lawful usage of these possibilities for tax liability optimization and increase of company profits. Major part of the thesis is dedicated to theoretical ways of international tax planning utilization for selected model. Cyprus, Ireland and Netherlands are included among main surveyed countries. There are described ways how can be reduced most effectively the tax liability of selected active and passive incomes.

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.

International tax planning deals with the tax benefits, their seeking and using by the tax entities and corporations. Even if the tax havens are generally considered as small islands, the different types of tax advantages are offered by the developed countries of the North America or Europe. This paper focuses on the analysis of the inward of foreign direct investments into the European countries with the preferential tax regimes. It explains the relationship between the inward of the investments and the factors which affect them. The inward of the foreign direct investments is the dependent variable, the independent variables are tax rates on corporate income, unemployment, as well as political stability. Although results of econometric analysis did not confirm our initial hypothesis that the lower tax burden will increase the inward of the investments to the country, this increase can be caused under the other circumstances, such as secrecy, property protection, stable political situation or simplicity and utility of the financial markets.

Tax evasion is one of the world's societal problems, which annually contributes to distorted competition when large tax amounts disappear from welfares. High-income earners and companies have managed to minimize tax expenditures through systematic applications, which has been revealed recently by elements such as Panama Papers, Luxleaks and Swissleaks. Previous studies have highlighted a problem that clear boundaries between tax planning and tax evasion do not exist. Whether or not which tax techniques and methods that are compatible with the law has been expressed as a difficulty in understanding the profession of accountants but also in professions such as tax advisers and accounting consultants. The purpose of the study was to investigate how auditors handle the issues regarding the gray zones between tax planning and tax evasion. The study's intention was to review previous legal cases and companies' audit reports to see how auditors have acted and how the court assessed complex legal cases, which were then supplemented with an interview study. This because when reviewing the cases, attention was drawn to the results that led us to interviews in order to take part in the auditor's perspective on the matter. The study was based on a qualitative research method where the results showed that auditors should consult more complex tax procedures with other auditors and tax lawyers to avoid legal consequences. The results further showed how important it is for auditors to keep constantly updated by legislation and regulations as these tend to change over time. The result also showed that auditors should act restrictively and judiciously and have a strict attitude in their working methods for minimizing undesirable situations where irregularities can occur. Auditors must also have a well-designed audit plan to avoid the risk of material errors slipping through the audit.

This master thesis attempts to contribute to the existing earnings management literature by examining whether tax avoidance incentives affect opportunistic accounting choices in distress conditions. To address this issue, it investigates 2668 companies in the quarters around breach of debt covenant spanning from 1996 to 2006. This allows to analyze two distress scenarios: first, whether the companies having the opportunity to minimize tax expenses and thus improve their financial stability, would deliberately switch from engaging in aggressive upwards real earnings management to tax considerations to mitigate the potential consequences of technical default; second, whether the companies facing increased lender's scrutiny after subsequent violation are compelled to switch by the creditor. The results indicate that tax considerations do not deter misreporting in the quarters around debt covenant violation. This thesis further provides evidence against the debt covenant hypothesis: the companies in the analyzed sample engaged in negative revenue manipulation in the quarters of new breach of debt covenant and in the quarters in which the firms remained in violation. In additional analysis, it was found that the above relationship is more prominent for the companies exhibiting poor financial performance.

This thesis investigates if the tax rate on dividend income has a significant effect on private consumption expenditure. This is done through a panel study on 36 OECD countries during the period 2000-2019. Regressions using differenced data and several control variables are used. The results are to some extent in line with previous empirical work studying the effects of tax changes on consumption. The results indicate that the taxation of capital income in the form of the overall tax rate on dividend income does not have a significant effect on private consumption expenditure. The theoretical mechanism deemed most likely to be in effect is tax planning since contradictory results are obtained regarding the effects of other tax rates in the form of taxes on labour income and VAT on private consumption expenditure.

Выпускная квалификационная работа (магистерская диссертация) посвящена исследованию налогового планирования и налоговой оптимизации на предприятии. Предметом исследования выступают совокупность экономических отношений, направленных на деятельность предприятия по налоговому планированию и налоговой оптимизации. Основной целью магистерской диссертации является разработка теоретических положений по налоговому планированию и практических рекомендаций по проблеме налогового планирования и налоговой оптимизации. / Tax planning for many became one more source of financing and also a factor, increasing competitiveness of the produced goods and services. Heads are interested more in a tax planning, in tax minimization by lawful or illegal methods, as economy on tax payments in fact it is a reserve for increase in profit and consequently, increases in dividends. In these conditions, the importance tax planning increases every day.

There are currently two methods states generally use to tax the income of multistate multi-corporate businesses. One is separate accounting, and the other is the unitary method. Virginia currently uses separate accounting to tax such income. Under separate accounting businesses have greater ability to avoid state income tax with (1) their choice of corporate organization (branches or affiliates) and filing methods, and (2) transfer price manipulations. The objectives of the research were to (1) measure the incentive provided multistate businesses to utilize corporate organization and filing methods as a tax planning tool, and (2) measure the extent to which current Virginia law helps multistate businesses to avoid tax in Virginia and other states. Computer models were developed to compute the total state tax liability of a hypothetical representative multistate business which operated in Virginia and two other states. The models were utilized to compute the Virginia and total state tax for the business in 1,053 different situations. To measure the incentive provided multistate businesses to utilize corporate organization and filing methods as a tax planning tool, a comparison was made of the state tax liability of a business which made elections that minimized its tax with the tax liability of a similar business which made elections that maximized its tax. The tax avoidable under current Virginia law with corporate organization and filing method planning was measured by comparing the business's minimized tax under current law with its minimized tax under the assumption that Virginia utilized the unitary method. The effectiveness of current Virginia law in limiting the ability of businesses to use transfer price manipulations to reduce their state tax liabilities was measured by comparing the effects of a given transfer price manipulation between current law and the unitary method. The results of the analyses show that businesses have a clear incentive to utilize corporate organization and filing method planning, and that current Virginia law makes a substantial contribution to the ability of businesses to avoid state income tax. / Ph. D.

No description available.

This thesis analyzes the concept of corporate residence, with particular reference to the law in the UK and Canada. It explores why corporate residence is relevant in tax policy, how corporate residence is understood in law, and how revenue authorities respond to the use and alleged 'abuse' of residence rules. Part I argues that the residence of taxpayers generally (individual or corporate) remains a relevant factor in international tax design, that taxation of corporations on the basis of residence has some justification, but that there is a disjunction between meaningful residence-based taxation and current definitions of corporate residence in domestic law and tax treaties. The formulations of residence based on incorporation, central management and control, and place of effective management, particularly as applied to multinational enterprises, are considered and are found to be deficient. Part II critically analyzes the major policy responses of the UK and Canadian governments to the exploitation of corporate residence. It argues that key legislative and administrative responses to international tax avoidance activities, for both outbound and inbound investment, are purportedly based on the acceptance of formal corporate residence yet undermine that concept in an effort to impose tax or refuse treaty relief based on where economic interests actually exist. The responses considered are the application of controlled foreign companies legislation to offshore subsidiaries, the invocation of treaty anti-abuse rules with respect to offshore intermediaries, and the use of overarching general anti-avoidance measures to challenge varied structures that rely on offshore entities. These haphazard anti-avoidance rules are overlaid with revenue authorities' indignation at the motivations that underlie many corporate relocations. It is argued that a more coherent approach would be to focus on the objective reality or unreality of corporate establishment, by reformulating corporate residence in domestic law and tax treaties.