This thesis comprises of a theoretical taxation background of German and Dutch holding companies with respect to the Czech Republic. It analyzes different incomes generated by the holding companies and focuses on comparison of possible tax scenarios. The scope of the work extends beyond mere description and analysis of relevant taxation - it attempts to add value by comparing advantages and disadvantages of the aforesaid countries for establishing a holding company. The work has always its firm foundations in the Czech legislation and continues to scrutinize a network of international double taxation treaties and a system of European directives. The core lies in analysis of different holding structures and in analysis of different income taxation, in particular income from dividends, capital gains, interests and royalties. Additionally, the thesis touches on issues related to permanent establishments, transparent entities and beneficial owners of the entire holdings. There are three real-based examples of individuals or entities which plan on establishing a holding company either in Germany or in the Netherlands and follows their decision making process. They are (i) US based software producer, (ii) individual investor in organic farming, and (iii) investment fund with minority shares in projects....
| Identifer | oai:union.ndltd.org:nusl.cz/oai:invenio.nusl.cz:305488 |
| Date | January 2012 |
| Creators | Ryneš, Oto |
| 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 |
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