Aspekty mezinárodního zdanění příjmů ze samostatné činnosti

Abstract

The title of this master thesis is Aspects of International Taxation of Income from Self-Employment and its aim is to suggest possible ways of how to proceed with international dual taxation. This situation arises when a self-employment is practiced by a ratepayer in two states simultaneously. This thesis is divided into two main parts. In the first part, there are theoretical principles mentioned, while the second part describes their application together with filling appropriate tax forms. The thesis also includes an explanation of basic tax terms and characteristics of international tax conventions, as well as its historical development. This is followed by a model tax convention on the elimination of double taxation with brief introduction of its basic parts and terms. This contract is a model for international conventions that are concluded between two states. Apart from that, there are also steps for establishing firstly, the country for tax residence and secondly, what creates the permanent establishment. The third chapter describes a ratepayer’s active and passive incomes and also methods of how to avoid double taxation including its application. There is also a description of each kind of income that is liable to tax. The incomes relate to both residents and non-residents. Ways of how to tax these incomes together with illustrative examples are also included. The practical part introduces three different people and each of them is in a different situation. The first person is a resident of the Czech Republic, the second one is a resident of Switzerland and the third person is a resident of a third country. Firstly, methods of double taxation elimination are applied. Secondly, tax returns of these three people are filled. At the end, each single case is commented.