Course detail

International Taxation of Incomes

FP-FitiKAcad. year: 2026/2027

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

English

Number of ECTS credits

4

Mode of study

Not applicable.

Guarantor

doc. Ing. Mgr. Karel Brychta, Ph.D.

Department

Institute of Finances (ÚF)

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

Not applicable.

Prerequisites and corequisites

Not applicable.

Basic literature

OECD (2019), Model Tax Convention on Income and on Capital 2017 (Full Version), OECD Publishing, Paris, https://doi.org/10.1787/g2g972ee-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.
LANG, Michael. Introduction to the law of double taxation conventions. Amsterdam: IBFD, 2010, 222 p. 1st edition. ISBN 90-872-2082-0.

Recommended reading

BRYCHTA, K. Assessment of Consistency of the Czech Tax Law with European Union Law with a View to Non-Residents Taxation. ACTA VŠFS. 2011. 5(1). p. 74 - 92. ISSN 1802-792X.
Lang, Michael [et al.] Introduction to European Tax Law on Direct Taxation. 8th ed. London: Spiramus Press, 2025. ISBN 9781913507770. 

Classification of course in study plans

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

Type of course unit

 

Guided consultation in combined form of studies

12 hours, optionally

Teacher / Lecturer

doc. Ing. Mgr. Karel Brychta, Ph.D.

Syllabus

1. International taxation of incomes – general introduction (basic terms, legal regulation, specificity of the situation in the EU, subjects „operating“ in the international taxation of incomes).
2. Double tax treaties (essence, objects, model treaties, structure of the treaties, scope, princip of conditional application priority).
3. Tax residency and its determination, tax residents and taxation of their incomes (in general), tax non-residents and taxation of their incomes (in general), conversion of currency.
4. Taxation of incomes of tax non-residents from the sources in the Czech Republic (duties of payers, duties of tax-payers, possibilities of tax optimization for tax non-residents of the Czech Republic compared to tax residents of the Czech Republic).
5. Rules for taxation of selected incomes as stated in double tax treaties – incomes from immovable property, capital gains, incomes from employment
6. Rules for taxation of selected incomes as stated in double tax treaties – director´s fees, enternainers and sportspersons, pensions.
7. Rules for taxation of selected incomes as stated in double tax treaties – taxation of business profits.
8. Rules for taxation of selected incomes as stated in double tax treaties – dividends, interest and royalties.
9. Taxation of tax residents – methods for avoidance of double taxation (description, principles, Article 38f of Act on Income Taxes).
10. Taxation of tax residents – application of methods for avoidance of double taxation.
11. Introduction to European tax law in direct taxes.
12. Reflexion of EU direct tax law in Czech tax acts.
13. European Court of Justice case law in international taxation of incomes.

Individual preparation for an ending of the course

52 hours, optionally

Teacher / Lecturer

doc. Ing. Mgr. Karel Brychta, Ph.D.

Self-study

37 hours, optionally

Teacher / Lecturer

doc. Ing. Mgr. Karel Brychta, Ph.D.