Změna režimu z pohledu českého, britského a německého zákona o DPH

Abstract

The aim of my thesis is to give a comprehensive overview of the VAT issues upon the registration and deregistration as VAT payer from the perspective of Czech, British and German VAT Act. At first I have defined the valid legislation to this tax in all three countries, including the directives, which deepen harmonization in the VAT area within the European Union. Further I explain the basic terms closely related to the given issues, namely using the Czech VAT Act. In second part of the thesis the specific issues are solved, namely separately for the Czech Republic, Great Britain and Germany. I mention the conditions, under which it is possible to claim the deduction entitlement to full extent, as the case may be to reduced extent, and the conditions for acknowledgement of the deduction entitlement for the purchases carried out before registration. In connection with the registration and deregistration, it is also necessary for the legislatively specified assets to carry out different modifications of the originally claimed deduction determined on the basis of their intended use for taxable supplies if a change occurs in the future. In case of the entrepreneurial activity termination, it is the payer’s duty to levy the output tax for the assets registered as of the registration cancellation date. I describe the ways of solving particular calculations, the conditions for gaining of the respective advantage, the taxation period length and form of VAT return for each country separately. In the last part I have carried out application on specific examples with the aim of subsequent evaluation and comparison of the possibilities the separate countries offer for the solutions of registration and deregistration. I have illustrated the calculations on the basis of exceeding of the turnover, which constitutes the creation of the VAT registration duty in Great Britain and in the Czech Republic. Then a separate example to show the regulation of the deduction in Germany follows. For clearly theoretical comparison of the differences among the countries I have used an example concerning the registration cancellation for the reason of entrepreneurial activity termination. On the basis of the results found out, the biggest advantages are provided to the payer upon registration in the Great Britain, upon deregistration the situation is quite similar in Germany and in the Czech Republic. Application of German VAT Act seems a little bit more advantageous.