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FP-FmdsPAcad. year: 2025/2026
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.
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Rules for evaluation and completion of the course
PASSING THE COURSEThe course is completed with a credit and an exam. 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 (60 minutes)The credit week is reserved for the term of remedial credit tests.ExamExamination (written) focused on demonstration of the theoretical knowledge gained (ten open questions – max. 40 points; 4 points per question). (75 minutes). To pass the exam, at least 50 % points shall be reached.Final classificationThe 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.Attendance at lectures is not compulsory. Attendance in seminars is compulsory and active participation on the part of the students is required. Excluding seminars set for the credit tests one absence of a student is tolerated.
PASSING THE COURSE FOR THE STUDENTS WITH APPROVED INDIVIDUAL STUDY PLANCredit: elaboration of partial tasks presented in the e-learning and graduation of two control credit tests (on conditions as stated above). Exam: on conditions as specified above.
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Syllabus
1. Tax systems and their development - basic terms definitions; tax system determinants; current state and trends; tax systems benchmarking.2. OECD project against BEPS (Base Erosion and Profit Shifting) - Actions Plans and their impact on tax systems.3. International Taxation of Incomes - introduction; legal regulation; double tax treaties; their classification, structure, goals, scope and interpretation.4. Double Tax Treaty applicaiton (Art. 1 - 7 of the OECD Model Convention).5. Double Tax Treaty application (rules for taxation of active and passive incomes). 6. Double Tax Treaty application - other provisions in DTT and their influence for tax issues (prohibition of discrimination, tax dispute resolution, most-favoured-clause treatment, mixed provisions).7. EU Tax Law - introduction (primary law; determinants for EU tax law; goals of the EU and her tax policy; EU bodie and their roles for tax area).8. EU Tax Law - direct taxes I.9. EU Tax Law - direct taxes II.10. EU Tax Law - indirect taxes I.11. EU Tax Law - indirect taxes II.12. Transfer Pricing - terminology; international, EU and domestic legal regulation.13. Transfer Pricing - methods for setting a transfer price; selected case-law of Czech Courts related to transfer pricing.
Exercise