Provádění programu ATAD

Knetl, Štěpán

The aim of the thesis is to describe and evaluate the Czech implementation of Anti-Tax Avoidance Directive (ATAD). It firstly introduces the problem of tax avoidance, its scale and defines basic concepts such as tax avoidance, tax evasion, tax havens and harmful preferential tax regimes. The author consequently describes origins of the Directive, OECD's Base Erosion and Profit Shifting Actions and other measures that are being implemented on the EU level such as international exchange of information in the field of taxation based on DAC Directives, the proposal of CCCTB. In the second chapter the ATAD is presented. It consists of five measures intended to neutralize the effects of tax avoidance practices, or in other words, to prevent erosion of the CIT base and the shifting of profits to jurisdictions enforcing little or no tax liabilities. First measure proposed is the interest limitation rule. It is intended to prevent the use of debt financing as a form of tax avoidance by limiting the amount of the tax-deductible borrowing costs that an entity is allowed to claim. Second measure is the exit taxation rule that requires the Member States to tax unrealised appreciation of assets based on the difference between amount equal to the market value of the transferred asset at the time of exit of the...

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