Analýza aspektů mezinárodního zdanění

Abstract

The main goal of this master thesis is to provide an overview of international taxation issues. The Czech Republic and The Netherlands take the biggest part in the following cases. A partial goal is to analyze and go into associated legislation. Crucial legislation is a model tax convention on income and on capital or the EU Parent-Subsidiary Directive for companies within the European Union. An important part of the thesis are cases with a focus on taxation of dividends or royalties within a holding company. The last case takes a closer look at a well-known strategy „Double Irish with Dutch Sandwich“ for profit shifting and tax avoidance.