Course detail
International Tax Systems
FP-FmdsKAcad. year: 2018/2019
Tax Systems. International Taxation of Incomes. Harmonization of Tax Systems in the EU – area of direct taxes, area of indirect taxes, reflexion of EU legal regulations in Czech law. Optimization of the tax burden in the context of international taxation. International Tax Planning. Transfer pricing.
Language of instruction
Number of ECTS credits
Mode of study
Guarantor
Department
Learning outcomes of the course unit
Skills: The student is able to comprehensively evaluate the current state and anticipated future developments in the tax field, apply legal norms regulating the international taxation of income, propose steps leading to international tax optimisation, identify risks in the international taxation of income and propose steps toward their elimination, determine the tax liability of tax residents of the Czech Republic receiving various categories of income from abroad, as well as the tax liabilities of tax non-residents of the Czech Republic receiving various categories of income from sources on the territory of the Czech Republic (including completing the relevant tax returns and/or reports).
Abilities: The student can independently solve tasks, the aim of which is international tax optimisation, comprehensively and convincingly convey information concerning the possibilities of international tax optimisation, possible risks and means of their elimination and objectively and rationally justify opinions with reference to the relevant legislation.
Prerequisites
Co-requisites
Planned learning activities and teaching methods
Assesment methods and criteria linked to learning outcomes
The credit is conditioned by:
a) Active participation at the seminars.
b) Passing of two control credit tests (examples); it is necessary to gain at least 50 % in each credit test.
- 1st test: max. 15 points (70 minutes)
- 2nd test: max. 15 points (70 minutes)
The credit week is reserved for the term of remedial credit tests.
Exam
Examination (written) focused on demonstration of the theoretical knowledge gained (ten open questions – max. 40 points; 4 points per question). (75 minutes).
Final classification
The exam is classified according to the ECTS scale.
The final evaluation of the course is influenced by work during the semester (see below).
Maximum possible points in total: 70 points
- credit tests: max. 30 points
- exam test: max. 40 points.
Course curriculum
2. Comparison of states from the perspective of their tax systems, tax competition, tax coordination, tax reforms and their classification, establishing ‘modern’ tax systems, fiscal termites.
3. International taxation of incomes – introduction to the issues, legal regulation, agreements on avoidance of double taxation, their classification, structure, objectives applicability and interpretation.
4. Application of agreements on avoidance of double taxation (Art. 1 – Art. 7 MS OECD).
5. Application of agreements on avoidance of double taxation (regulations for taxing active and passive incomes).
6. Application of agreements on avoidance of double taxation – additional clauses in agreements on avoidance of double taxation and their influence on solving tax issues (prohibition of discrimination, exchange of information, resolving cases by mutual agreement, MFN clauses, mixed provisions).
7. EU tax law – introduction to issues (the norms of primary tax law in the EU, determinants of development in the tax field in the EU, EU objectives and tax policy, EU bodies and their role in the tax field).
8. EU tax law EU – EU secondary legislation (directive removing obstacles, directive deepening cooperation and adjustment of social insurance).
9. EU tax law – indirect taxes (excise taxes – excise and energy taxes and their reflection in the Czech legal order).
10. International tax planning and optimisation – describing basic concepts, boundaries and limits, activity of international organisations (BEPS, etc.).
11. International tax planning and optimisation – the concept of international tax planning, profit drivers, approaches to the creation of international tax strategy, key areas in international tax planning (e.g. the creation of holding structures, management of intangible assets), tax paradises (classification, their use).
12. Transfer pricing – describing basic concepts, regulation in international, EU and domestic law, methods for establishing transfer prices, etc.
13. Selected issues from the international taxation of income (the rule of low market capitalisation, reclassification of interest, developments in case-law, etc.).
Work placements
Aims
Specification of controlled education, way of implementation and compensation for absences
Recommended optional programme components
Prerequisites and corequisites
Basic literature
Recommended reading
Classification of course in study plans
- Programme MGR-KS Master's
branch MGR-UFRP-KS , 2 year of study, winter semester, compulsory
Type of course unit
Guided consultation in combined form of studies
Teacher / Lecturer
Syllabus
2. Comparison of states from the perspective of their tax systems, tax competition, tax coordination, tax reforms and their classification, establishing ‘modern’ tax systems, fiscal termites.
3. International taxation of incomes – introduction to the issues, legal regulation, agreements on avoidance of double taxation, their classification, structure, objectives applicability and interpretation.
4. Application of agreements on avoidance of double taxation (Art. 1 – Art. 7 MS OECD).
5. Application of agreements on avoidance of double taxation (regulations for taxing active and passive incomes).
6. Application of agreements on avoidance of double taxation – additional clauses in agreements on avoidance of double taxation and their influence on solving tax issues (prohibition of discrimination, exchange of information, resolving cases by mutual agreement, MFN clauses, mixed provisions).
7. EU tax law – introduction to issues (the norms of primary tax law in the EU, determinants of development in the tax field in the EU, EU objectives and tax policy, EU bodies and their role in the tax field).
8. EU tax law EU – EU secondary legislation (directive removing obstacles, directive deepening cooperation and adjustment of social insurance).
9. EU tax law – indirect taxes (excise taxes – excise and energy taxes and their reflection in the Czech legal order).
10. International tax planning and optimisation – describing basic concepts, boundaries and limits, activity of international organisations (BEPS, etc.).
11. International tax planning and optimisation – the concept of international tax planning, profit drivers, approaches to the creation of international tax strategy, key areas in international tax planning (e.g. the creation of holding structures, management of intangible assets), tax paradises (classification, their use).
12. Transfer pricing – describing basic concepts, regulation in international, EU and domestic law, methods for establishing transfer prices, etc.
13. Selected issues from the international taxation of income (the rule of low market capitalisation, reclassification of interest, developments in case-law, etc.).