Return to search

Smlouvy o zamezení dvojího zdanění a možnosti jejich zneužití / Double taxation avoidance treaties and their potential abuse

In recent years, number of initiatives arised from the European Union and OECD towards active cooperation and coordination between countries in the fight against international tax avoidance practices. The abuse of double taxation treaties and tax legislation in general became subject of increasing interest also among the Czech professional public. The aim of my thesis is to examine whether and to what extent double taxation tax treaties are used by taxpayers for purposes other than those originally negotiated between states, explore what are the tools that can prevent abuse of tax treaties and to assess whether tools used in the Czech Republic correspond to international standards and whether there is scope for more effective aplication of these tools with regard to international practice. As my research within international context showed, there are a number of anti avoidance rules against abuse of tax treaties and tax avoidance in general. The anti avoidance rules are incorporated in national substantive and procedural legislation, as well as in international law. Other relevant anti avoidance rules are elaborated by the courts. Effective tool to prevent undesirable international tax practices is, not least, international cooperation, and especially timely and relevant exchange of tax...

Identiferoai:union.ndltd.org:nusl.cz/oai:invenio.nusl.cz:306543
Date January 2012
CreatorsIshchenko, Iryna
ContributorsMarková, Hana, Kohajda, Michael
Source SetsCzech ETDs
LanguageCzech
Detected LanguageEnglish
Typeinfo:eu-repo/semantics/masterThesis
Rightsinfo:eu-repo/semantics/restrictedAccess

Page generated in 0.0017 seconds