Mezinárodní zdanění ve vztahu ke vzniku stálých provozoven v jiných členských státech Evropské unie

Abstract

The Diploma thesis deals with international taxation in respect of permanent establishments in other Member States of the European Union. The aim of the work is to analyze this issue through agreements for the avoidance of double taxation between the Czech Republic and other Member of the European Union. The part of the thesis is focused on theoretical knowledge of an international double taxation, concept of agreements for the avoidance of double taxation, definition of the term „permanent establishment“ and its concept on the basis of the OECD model tax convention (Organisation for Economic Co-Operation and Develepment) and the taxation of permanent establishment. The work practically done evaluation of the impact of a permanent establishment in the Slovak Republic and Germany.