Course detail

International Taxation of Incomes

FP-FitiPAAcad. year: 2023/2024

The course deals with the issue of the international taxation of income. In this course students are familiarized with the problems of international double taxation and methods for its elimination. Attention is also paid to legislative regulation in the European Union.

Language of instruction

English

Number of ECTS credits

3

Mode of study

Not applicable.

Entry knowledge

Knowledge of issues in the taxation of the incomes of individuals and legal entities.

Rules for evaluation and completion of the course

Examination requirements: knowledge of the material covered and its practical application.

The course ends with a written examination which is made up of two main parts:

1. Written test (test contains 15 questions with 3 possible answers (A, B, C); only one answer is correct). It is necessary to get at least 50% of the possible points (i.e. at least 8 points out of 15). The test takes 15 minutes.
- correct answer (1 point)
- no answer (0 point)
- incorrect answer (- 1 point)

2. Examples – max. 30 points (75 min.)
- solving numerical examples demonstrating familiarity with the issues and the practical ability to apply the lessons learned
- always a more complex example to determine the resulting tax liability of tax resident from receiving foreign income
- it is necessary to gain at least 50% of the possible points (i.e. 15 points out of 30)

The examination is classified according to the ECTS scale.

Aims

The main objective of the course is not only to provide students with the theoretical fundamentals of the issues of the international taxation of income, but also the ability to apply practically the knowledge gained. This requires knowledge of the principles of international taxation of income and also the specific rules contained in agreements on double taxation, as well as the relevant Czech legislation.
Students will know the rules of the international taxation of income contained in agreements on the avoidance of double taxation as well as in Czech legislation. Students at the same time will know the duties of tax subjects falling under the international taxation of income in the Czech Republic.

Students will be able to identify the duties linked to the taxation of the income of tax residents and non-residents of the Czech Republic and in simpler cases determine their resulting tax liabilities.

Students will know how to interpret and apply the basic norms of the international taxation of income in agreements on the avoidance of double taxation and in the Czech Income Tax Act. Students will know how to propose and use the instruments of tax optimisation in the international taxation of income.

Study aids

Not applicable.

Prerequisites and corequisites

Not applicable.

Basic literature

LANG, Michael. Introduction to the law of double taxation conventions. Amsterdam: IBFD, 2010, 222 p. 1st edition. ISBN 90-872-2082-0.
OECD (2017), Model Tax Convention on Income and on Capital: Condensed Version 2017, OECD Publishing, Paris. Dostupné z: http://dx.doi.org/10.1787/mtc_cond-2017-en.
BRYCHTA, K. Development of the Legislative Regulation of the Taxation of Income of Non-Residents in Transitional Economies – The Case of the Czech Republic. Transformations in Business & Economics. 2013. 12(3). p. 72 - 92. ISSN 1648-4460.

Recommended reading

LANG, Michael, Pasquale PISTONE, Josef SCHUCH a Claus STARINGER. Introduction to European tax law on direct taxation. 2nd ed. Wien: Linde, 2010, 223 s. ISBN 978-3-7073-1764-0.
SOJKA, Vlastimil, Monika BARTOŠOVÁ, Pavel FEKAR, Jan MAŠEK, Matěj NEŠLEHA a Ivana VAŇOUSOVÁ. Mezinárodní zdanění příjmů: smlouvy o zamezení dvojího zdanění a zákon o daních z příjmů. 4. vydání. Praha: Wolters Kluwer, 2017. Daně. ISBN 978-80-7552-688-5.

Classification of course in study plans

  • Programme MGR-UFRP-A Master's, 1. year of study, summer semester, compulsory-optional

Type of course unit

 

Lecture

26 hours, optionally

Teacher / Lecturer

Guided consultation in combined form of studies

12 hours, optionally

Teacher / Lecturer