Mezinárodní pronájem pracovních sil

Abstract

Diploma thesis is focused on International Hiring Out of Labour (IHOL). IHOL is one of the structures of posting employees mainly abroad.

The chapter regarding international double taxation is important part of this diploma thesis. In this chapter are explained important terms for the purposes of this diploma thesis such as tax resident and tax non-resident, permanent establishment and also instruments to avoid the double taxation. Next theoretical chapter is focused on the IHOL itself. There are explained basic characteristics, the criteria determining that it is IHOL and also the terms and conditions that should be set. It also explains the obligations that can be taken by an individual involved parties from the application of IHOL.

The theoretical basis was subsequently applied to the practical situation in the last chapter, where the parent company hired out the employees to its subsidiary company. All the obligations caused by application of hiring out of labour for the individual subjects were defined. In the end of the pracitcal chapter was calculated the annual tax liability of one of the posted employees.