Diplomová práce: Beneficiární vlastník v daňovém právu Abstrakt v anglickém jazyce BENEFICIAL OWNER IN TAX LAW In many instances, the concept of beneficial owner can be found in tax law, enabling the taxpayers to lower the taxation of their income. Despite the fact that the term beneficial owner is not very commonly used in the Czech law, interpretation of this term is important part of the international tax law. Therefore, the purpose of my Theses is to review relevant laws (including Czech tax law, international tax law, European law, and relevant Czech and international court's decisions) to determine common characteristics of the term beneficial owner as it is used in the above mentioned fields of law. In the European law, the term beneficial owner can be found in two European directives - "Interest and royalty payments directive" and "Income savings directive". Although there are differences between the interpretation on the term beneficial owner in these European directives (based mostly on the fact that one directive is applicable to natural persons whereas the other one to legal entities), we can say that the purpose and aim of the regulation is the same. The OECD and its fiscal committee are concern with the interpretation and appropriate application of the term beneficial owner in the...
| Identifer | oai:union.ndltd.org:nusl.cz/oai:invenio.nusl.cz:328301 |
| Date | January 2013 |
| Creators | Olšarová, Marie |
| Contributors | Novotný, Petr, Vondráčková, Pavlína |
| Source Sets | Czech ETDs |
| Language | Czech |
| Detected Language | English |
| Type | info:eu-repo/semantics/masterThesis |
| Rights | info:eu-repo/semantics/restrictedAccess |
Page generated in 0.0017 seconds