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Course detail
FP-FitiKAcad. year: 2025/2026
The course focuses on the issues of international income taxation. Students are introduced to the concept of international double taxation and the tools used to mitigate it. Attention is also partially given to legislation at the European Union level and to emerging trends in the field of international income taxation.
Language of instruction
Number of ECTS credits
Mode of study
Guarantor
Department
Entry knowledge
Knowledge of the basic principles of income taxation for individuals and legal entities.
Rules for evaluation and completion of the course
Examination Requirements: Knowledge of the covered material and its practical application.
The course is concluded with a written exam. The test includes a problem-solving section and open-ended questions aimed at assessing the understanding of key concepts, etc.
The maximum score is 20 points (test duration: 75 minutes).
To pass the exam, students must obtain at least 50% of the possible points.
The exam is graded according to the ECTS scale.
Students with an Individual Study Plan (ISP):
The same rules for course completion apply to students with an ISP. The exam date is set in accordance with the regulations specified in the approved ISP.
Aims
Learning Objectives:
Acquire theoretical foundations and practical skills in the field of international income taxation.
Understand the principles of international income taxation and the specific rules contained in double taxation treaties.
Have knowledge of the rules of international income taxation and the obligations of taxpayers.
Be able to identify the tax obligations of residents and non-residents.
Be able to interpret and apply the basic norms of international income taxation contained in double taxation treaties.
Be able to propose and utilize methods of tax optimization in the context of international income taxation.
Study aids
Prerequisites and corequisites
Basic literature
Recommended reading
Elearning
Classification of course in study plans
Guided consultation in combined form of studies
Teacher / Lecturer
Syllabus
Thematic Areas Cover:
International Income Taxation – General Introduction (basic concepts, legal framework, specifics of the EU context, entities in international income taxation).
Double Taxation Treaties (essence, objectives, model treaties, treaty structure, scope, principle of conditional application priority).
Tax Residence and Its Determination; taxation of residents’ income (general); taxation of non-residents’ income (general); currency conversions.
Taxation of Non-Residents’ Income from Sources in the Czech Republic (obligations of withholding agents, obligations of taxpayers, possibilities for tax optimization of non-residents compared to residents).
Rules for Taxing Selected Types of Income under Double Taxation Treaties – income from immovable property, income from the sale of property, employment income.
Rules for Taxing Selected Types of Income under Double Taxation Treaties – royalties, artists and athletes, pensions.
Rules for Taxing Selected Types of Income under Double Taxation Treaties – business income.
Rules for Taxing Selected Types of Income under Double Taxation Treaties – dividends, interest, and license fees.
Taxation of Residents – methods for eliminating double taxation.
Taxation of Residents – application of double taxation elimination methods.
Introduction to EU Tax Law in the Field of Direct Taxes.
Reflection of EU Tax Law in Direct Taxes within Czech Tax Legislation.
Case Law of the Court of Justice of the EU in International Income Taxation.
Self-study
Individual preparation for an ending of the course