The Tax System in the Czech Republic
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Analysis of Tax Developments Worldwide
www.pwc.com/its International Tax News Edition 78 August 2019 Welcome Keeping up with the constant flow of Featured articles international tax developments worldwide can be a real challenge for multinational companies. International Tax News is a monthly publication that offers updates and analysis on developments taking place around the world, authored by specialists in PwC’s global international tax network. We hope that you will find this publication helpful, and look forward to your comments. Bernard Moens Global Leader International Tax Services Network T: +1 703 362 7644 E: [email protected] In this issue Legislation Administrative Judicial EU/OECD Treaties Legislation Argentina Argentina approves tax regime for Among others, the following tax benefits knowledge-based activities apply to the extent that taxpayers comply with certain requirements: Law No. 27,506, published on June • 15% reduced corporate income tax rate 10, enacted a new regime promoting applicable to fiscal years beginning on or knowledge-based activities. The regime’s after January 1, 2020 main tax benefits include a reduced • executing tax stability agreements with federal corporate income tax rate of 15% and a tax authorities providing that the federal tax tax stability agreement. The new regime burden on income from Promoted Activities cannot increase until December 31, 2029 replaces the existing regime, which was • ability to claim withholding taxes, VAT limited to the software industry, and withholding exemptions, and reduction in will be effective from January 1, 2020 social security contributions through December 31, 2029. Multinational entities engaged in Promoted Activities should revisit their Argentinian operations in order to The new regime aims to encourage the creation, benefit from the new regime. -
Engagement Guidance on Corporate Tax Responsibility Why and How to Engage with Your Investee Companies
ENGAGEMENT GUIDANCE ON CORPORATE TAX RESPONSIBILITY WHY AND HOW TO ENGAGE WITH YOUR INVESTEE COMPANIES An investor initiative in partnership with UNEP Finance Initiative and UN Global Compact THE SIX PRINCIPLES We will incorporate ESG issues into investment analysis and 1 decision-making processes. We will be active owners and incorporate ESG issues into our 2 ownership policies and practices. We will seek appropriate disclosure on ESG issues by 3 the entities in which we invest. We will promote acceptance and implementation of the Principles 4 within the investment industry. We will work together to enhance our effectiveness in 5 implementing the Principles. We will each report on our activities and progress towards 6 implementing the Principles. CREDITS & ACKNOWLEDGEMENTS Authors: Athanasia Karananou and Anastasia Guha, PRI Editor: Mark Kolmar, PRI Design: Alessandro Boaretto, PRI The PRI is grateful to the investor taskforce on corporate tax responsibility for their contributions to the guidance: ■ Harriet Parker, Investment Analyst, Alliance Trust Investments ■ Steven Bryce, Investment Analyst, Arisaig Partners (Asia) Pte Ltd ■ Francois Meloche, Extra Financial Risks Manager, Bâtirente ■ Adam Kanzer, Managing Director, Domini Social Investments LLC ■ Pauline Lejay, SRI Officer, ERAFP ■ Meryam Omi, Head of Sustainability, Legal & General Investment Management ■ Robert Wilson, Research Analyst, MFS Investment Management ■ Michelle de Cordova, Director, Corporate Engagement & Public Policy, NEI Investments ■ Rosa van den Beemt, ESG Analyst, NEI Investments ■ Kate Elliot, Ethical Researcher, Rathbone Brothers Plc ■ Matthias Müller, Senior SI Analyst, RobecoSAM ■ Rosl Veltmeijer, Head of Research, Triodos Investment Management We would like to warmly thank Sol Picciotto, Emeritus Professor, Lancaster University and Coordinator, BEPS Monitoring Group, and Katherine Ng, PRI, for their contribution to the guidance. -
Creating Market Incentives for Greener Products Policy Manual for Eastern Partnership Countries
Creating Market Incentives for Greener Products Policy Manual for Eastern Partnership Countries Creating Incentives for Greener Products Policy Manual for Eastern Partnership Countries 2014 About the OECD The OECD is a unique forum where governments work together to address the economic, social and environmental challenges of globalisation. The OECD is also at the forefront of efforts to understand and to help governments respond to new developments and concerns, such as corporate governance, the information economy and the challenges of an ageing population. The Organisation provides a setting where governments can compare policy experiences, seek answers to common problems, identify good practice and work to co-ordinate domestic and international policies. The OECD member countries are: Australia, Austria, Belgium, Canada, Chile, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, the Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States. The European Union takes part in the work of the OECD. Since the 1990s, the OECD Task Force for the Implementation of the Environmental Action Programme (the EAP Task Force) has been supporting countries of Eastern Europe, Caucasus and Central Asia to reconcile their environment and economic goals. About the EaP GREEN programme The “Greening Economies in the European Union’s Eastern Neighbourhood” (EaP GREEN) programme aims to support the six Eastern Partnership countries to move towards green economy by decoupling economic growth from environmental degradation and resource depletion. The six EaP countries are: Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine. -
Alternative Approaches to Designing Financial Incentives
OECD PROJECT ON FINANCIAL INCENTIVES AND RETIREMENT SAVINGS POLICY BRIEF N°3 DECEMBER 2018 Alternative approaches to designing financial incentives The most common type of financial incentive savings are taxed upon withdrawal. In contrast, used by governments to promote savings for individuals would be better-off paying taxes retirement, is to defer taxation by taxing upfront when they expect tax rates during individuals only on their pension benefits retirement will be greater than when they are (“EET”). Governments are alternatively using working. other approaches to providing financial In the long run, upfront taxation may translate incentives, either through the tax system (e.g. into a higher fiscal cost than taxation upon upfront taxation or tax credits) or outside the tax withdrawal. Figure 2 compares the yearly fiscal system (e.g. matching contributions and fixed effects of the two tax regimes. It shows that, in nominal subsidies). the short term, upfront taxation leads to a lower Taxing retirement savings upfront or upon fiscal cost than taxation upon withdrawal. Taxing withdrawal only withdrawals and thus deferring tax collection, brings the full cost of tax revenues Taxing retirement savings upfront (i.e. taxing forgone on contributions upfront. With upfront only contributions, “TEE”) is often seen as an taxation, the fiscal cost is just equal to tax equivalent approach to taxing retirement savings revenues forgone on returns. In the long term, upon withdrawal (“EET”). Both tax regimes do once the two systems reach maturity, the fiscal indeed provide the same overall tax advantage to impact is reversed with taxation upon withdrawal individuals when their income is subject to the leading to a lower annual fiscal cost than upfront same marginal tax rate throughout working and taxation. -
With Indirect Tax News
InTouch with indirect tax news Caribbean Region – Alert pwc InTouch with indirect tax news Caribbean Region Alert In this issue: PricewaterhouseCoopers Caribbean Region is pleased I Antigua & Barbuda – Budgetary proposals legislated ............................3 to present the August 2010 I Aruba – BBO rate reduced......................................................................5 issue of InTouch, a bulletin I Barbados – Reforms to Barbados VAT ...................................................7 I Curaçao, Bonaire, St. Maarten, Saba, St. Eustatius...............................9 designed to keep our clients I Dominica ...............................................................................................10 up-to-date with regional I Grenada – VAT in Grenada effective February 1, 2010 .........................11 indirect taxation. I Jamaica – Increase in rate of GCT.......................................................12 I St. Kitts and Nevis – VAT proposed implementation ...........................14 I St. Lucia – Proposed introduction of VAT delayed...............................15 I Trinidad & Tobago ................................................................................16 I Contacts................................................................................................17 2 pwc Antigua & Barbuda Updates and developments An overview Rates 2009 saw the rate of Antigua and Barbuda Sales Antigua and Barbuda Sales Tax (“ABST”) is the The following rates of tax are applicable under the Tax (“ABST”) applicable -
European Parliament Resolution of 26 March 2019 on Financial Crimes, Tax Evasion and Tax Avoidance (2018/2121(INI)) (2021/C 108/02)
C 108/8 EN Official Journal of the European Union 26.3.2021 Tuesday 26 March 2019 P8_TA(2019)0240 Report on financial crimes, tax evasion and tax avoidance European Parliament resolution of 26 March 2019 on financial crimes, tax evasion and tax avoidance (2018/2121(INI)) (2021/C 108/02) The European Parliament, — having regard to Articles 4 and 13 of the Treaty on European Union (TEU), — having regard to Articles 107, 108, 113, 115 and 116 of the Treaty on the Functioning of the European Union (TFEU), — having regard to its decision of 1 March 2018 on setting up a special committee on financial crimes, tax evasion and tax avoidance (TAX3), and defining its responsibilities, numerical strength and term of office (1), — having regard to its TAXE committee resolution of 25 November 2015 (2) and its TAX2 committee resolution of 6 July 2016 (3) on tax rulings and other measures similar in nature or effect, — having regard to its resolution of 16 December 2015 with recommendations to the Commission on bringing transparency, coordination and convergence to corporate tax policies in the Union (4), — having regard to the results of the Committee of Inquiry into money laundering, tax avoidance and tax evasion, which were submitted to the Council and the Commission on 13 December 2017 (5), — having regard to the Commission’s follow-up to each of the above-mentioned Parliament resolutions (6), — having regard to the numerous revelations by investigative journalists, such as the LuxLeaks, the Panama Papers, the Paradise Papers and, more recently, the cum-ex scandals, as well as the money laundering cases involving, in particular, banks in Denmark, Estonia, Germany, Latvia, the Netherlands and the United Kingdom, — having regard to its resolution of 29 November 2018 on the cum-ex scandal: financial crime and loopholes in the current legal framework (7), (1) Decision of 1 March 2018 on setting up a special committee on financial crimes, tax evasion and tax avoidance (TAX3), and defining its responsibilities, numerical strength and term of office, Texts adopted, P8_TA(2018)0048. -
Tax Heavens: Methods and Tactics for Corporate Profit Shifting
Tax Heavens: Methods and Tactics for Corporate Profit Shifting By Mark Holtzblatt, Eva K. Jermakowicz and Barry J. Epstein MARK HOLTZBLATT, Ph.D., CPA, is an Associate Professor of Accounting at Cleveland State University in the Monte Ahuja College of Business, teaching In- ternational Accounting and Taxation at the graduate and undergraduate levels. axes paid to governments are among the most significant costs incurred by businesses and individuals. Tax planning evaluates various tax strategies in Torder to determine how to conduct business (and personal transactions) in ways that will reduce or eliminate taxes paid to various governments, with the objective, in the case of multinational corporations, of minimizing the aggregate of taxes paid worldwide. Well-managed entities appropriately attempt to minimize the taxes they pay while making sure they are in full compliance with applicable tax laws. This process—the legitimate lessening of income tax expense—is often EVA K. JERMAKOWICZ, Ph.D., CPA, is a referred to as tax avoidance, thus distinguishing it from tax evasion, which is illegal. Professor of Accounting and Chair of the Although to some listeners’ ears the term tax avoidance may sound pejorative, Accounting Department at Tennessee the practice is fully consistent with the valid, even paramount, goal of financial State University. management, which is to maximize returns to businesses’ ownership interests. Indeed, to do otherwise would represent nonfeasance in office by corporate managers and board members. Multinational corporations make several important decisions in which taxation is a very important factor, such as where to locate a foreign operation, what legal form the operations should assume and how the operations are to be financed. -
US-Steuerreform: Chancen Und Risiken: Wer Gewinnt – Wer Verliert?
ZUR DISKUSSION GESTELLT US-Steuerreform: Chancen und Risiken: Wer gewinnt – wer verliert? Die Steuerreform von US-Präsident Donald Trump sieht deutliche Steuersenkungen für Unternehmen und bescheidene Entlastungen für Privatpersonen vor. Vor allem Bezieher hoher Einkommen werden von der Reform profitieren. Zudem dürften die Staatsschulden nach vorläufigen Berechnungen über das kommende Jahrzehnt um mindestens eine Bil- lion Dollar anwachsen. Die Steuerreform wird aber auch voraussichtlich die Konjunktur in den USA anschieben, und sie wird den USA durch die Senkung der Unternehmensteuer- sätze einen massiven Wettbewerbsvorteil bescheren. Wie sollten die europäischen Länder reagieren? wirkungen auf effektive Unternehmensteuerbelas- Christoph Spengel*, Marcel Olbert** und tungen und die damit verbundenen Konsequen- Kathrin Stutzenberger*** zen, mögliche Folgen für die Entwicklung ausländi- scher Direktinvestitionen sowie auf das Verhältnis US-Steuerreform 2018 – der Reform zu aktuellen steuerpolitischen Entwick- Implikationen und lungen auf EU-Ebene eingegangen (vgl. Spengel et al. 2018). Konsequenzen für Europa1 AUSWIRKUNGEN DER US-STEUERREFORM AUF DIE Christoph Spengel Am 22. Dezember 2017 verabschiedete US-Präsident EFFEKTIVE UNTERNEHMENSTEUERBELASTUNG Donald Trump mit Unterzeichnung des »Tax Cuts and Jobs Act« die größte Reform des US-Steuersystems seit Die Konsequenzen der USSteuerreform für die effek- 1986. Diese sieht mit Wirkung ab dem 1. Januar 2018 auf tive Unternehmensteuerbelastung im Verhältnis zu Unternehmensebene neben einer -
More Than 50 Years of Trade Rule Discrimination on Taxation: How Trade with China Is Affected
MORE THAN 50 YEARS OF TRADE RULE DISCRIMINATION ON TAXATION: HOW TRADE WITH CHINA IS AFFECTED Trade Lawyers Advisory Group Terence P. Stewart, Esq. Eric P. Salonen, Esq. Patrick J. McDonough, Esq. Stewart and Stewart August 2007 Copyright © 2007 by The Trade Lawyers Advisory Group LLC This project is funded by a grant from the U.S. Small Business Administration (SBA). SBA’s funding should not be construed as an endorsement of any products, opinions or services. All SBA-funded projects are extended to the public on a nondiscriminatory basis. MORE THAN 50 YEARS OF TRADE RULE DISCRIMINATION ON TAXATION: HOW TRADE WITH CHINA IS AFFECTED TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY.............................................................................................. iv INTRODUCTION ................................................................................................................ 1 I. U.S. EXPORTERS AND PRODUCERS ARE COMPETITIVELY DISADVANTAGED BY THE DIFFERENTIAL TREATMENT OF DIRECT AND INDIRECT TAXES IN INTERNATIONAL TRADE .............................................. 2 II. HISTORICAL BACKGROUND TO THE DIFFERENTIAL TREATMENT OF INDIRECT AND DIRECT TAXES IN INTERNATIONAL TRADE WITH RESPECT TO BORDER ADJUSTABILITY................................................................. 21 A. Border Adjustability of Taxes ................................................................. 21 B. 18th and 19th Century Examples of the Application of Border Tax Adjustments ......................................................................... -
Potential Retaliation Against the EU Digital Services Tax (DST)
A Service of Leibniz-Informationszentrum econstor Wirtschaft Leibniz Information Centre Make Your Publications Visible. zbw for Economics Lee-Makiyama, Hosuk Research Report The cost of fiscal unilateralism: Potential retaliation against the EU Digital Services Tax (DST) ECIPE Occasional Paper, No. 05/2018 Provided in Cooperation with: European Centre for International Political Economy (ECIPE), Brussels Suggested Citation: Lee-Makiyama, Hosuk (2018) : The cost of fiscal unilateralism: Potential retaliation against the EU Digital Services Tax (DST), ECIPE Occasional Paper, No. 05/2018, European Centre for International Political Economy (ECIPE), Brussels This Version is available at: http://hdl.handle.net/10419/202461 Standard-Nutzungsbedingungen: Terms of use: Die Dokumente auf EconStor dürfen zu eigenen wissenschaftlichen Documents in EconStor may be saved and copied for your Zwecken und zum Privatgebrauch gespeichert und kopiert werden. personal and scholarly purposes. Sie dürfen die Dokumente nicht für öffentliche oder kommerzielle You are not to copy documents for public or commercial Zwecke vervielfältigen, öffentlich ausstellen, öffentlich zugänglich purposes, to exhibit the documents publicly, to make them machen, vertreiben oder anderweitig nutzen. publicly available on the internet, or to distribute or otherwise use the documents in public. Sofern die Verfasser die Dokumente unter Open-Content-Lizenzen (insbesondere CC-Lizenzen) zur Verfügung gestellt haben sollten, If the documents have been made available under an Open gelten abweichend von diesen Nutzungsbedingungen die in der dort Content Licence (especially Creative Commons Licences), you genannten Lizenz gewährten Nutzungsrechte. may exercise further usage rights as specified in the indicated licence. www.econstor.eu ECIPE OCCASIONAL PAPER • 05/2018 The Cost of Fiscal Unilateralism: Potential Retaliation Against the EU Digital Services Tax (DST) By Hosuk Lee-Makiyama Director of ECIPE The author gratefully acknowledges the able research assistance of Cristina Rujan ecipe occasional paper — no. -
The Relationship Between MNE Tax Haven Use and FDI Into Developing Economies Characterized by Capital Flight
1 The relationship between MNE tax haven use and FDI into developing economies characterized by capital flight By Ali Ahmed, Chris Jones and Yama Temouri* The use of tax havens by multinationals is a pervasive activity in international business. However, we know little about the complementary relationship between tax haven use and foreign direct investment (FDI) in the developing world. Drawing on internalization theory, we develop a conceptual framework that explores this relationship and allows us to contribute to the literature on the determinants of tax haven use by developed-country multinationals. Using a large, firm-level data set, we test the model and find a strong positive association between tax haven use and FDI into countries characterized by low economic development and extreme levels of capital flight. This paper contributes to the literature by adding an important dimension to our understanding of the motives for which MNEs invest in tax havens and has important policy implications at both the domestic and the international level. Keywords: capital flight, economic development, institutions, tax havens, wealth extraction 1. Introduction Multinational enterprises (MNEs) from the developed world own different types of subsidiaries in increasingly complex networks across the globe. Some of the foreign host locations are characterized by light-touch regulation and secrecy, as well as low tax rates on financial capital. These so-called tax havens have received widespread media attention in recent years. In this paper, we explore the relationship between tax haven use and foreign direct investment (FDI) in developing countries, which are often characterized by weak institutions, market imperfections and a propensity for significant capital flight. -
September 15, 2020 What's in and What's out of the Final 2020 Tax
September 15, 2020 What’s In and What’s Out of the Final 2020 Tax Package The 2020 tax package (HB 7097) was amended many times as it moved through the process. At first it grew, topping $230 million in tax savings at one point. Then, citing a need to keep more money in reserves for COVID-19 response, it started getting smaller. The total of the final tax package is $47.4 million, $10.8 million of which is local. All of the savings comes from two sales tax holidays, so the tax cuts are one-time. This reduces the tax package's fiscal hit to the state to $36.6 million in the upcoming budget year, with no recurring impact. The original tax package, developed in the House Ways and Means Committee, contained a mix of tax cuts and tax The Evolving Tax Package administration changes. Most of the cuts were small. The Version Tax Savings two largest tax cuts in the bill were both Florida TaxWatch House Ways & Means $167.2 priorities--a reduction in the communication services tax House Appropriations $193.4 (CST) of 0.5 percent and a reduction in the business rent tax Passed by House $198.4 (BRT) from 5.5 percent to 5.4 percent. The original bill Senate Appropriations $233.7 Senate 2nd Reading $107.1 would have reduced state and local taxes by $162.7 million Final Bill $47.4 (the sum of the one-time cuts and the recurring cuts1). More cuts were added in House the Appropriations Committee, pushing the total to $193.4 million.