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The course provides enhanced explication of legal and extra-legal issues arising in international taxation of
income. It focuses on international legal double taxation, its causes and effects, as well as the tools and instruments for the elimination or at least moderation of the same, including the instruments contained in international double taxation treaties (DTTs). Students will become acquainted with basic notions, terminology, and sources of international tax law. They will work with the texts of model treaties on elimination of double taxation as well as selected bilateral treaties actually concluded and applied between various countries. They will learn to find, interpret, and apply relevant rules of elimination of international double taxation and will be given the opportunity of learning how to resolve selected practical situations by application of gained skills and knowledge. The course is not strongly based on positive law of the Czech Republic or any particular country, and the competences gained in it by the students can thus be utilized in any jurisdiction in which they may operate in the future. Poslední úprava: Sojka Miroslav, Mgr. (25.06.2024)
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Examination will consist of a written test (closed-book, multiple choice test) that will be taken on 2024-12-17 or 2025-01-14 at 1600 hrs. Registration for one of the exam dates MUST be done via Moodle or by email to Petr Kotáb at kotabp@prf.cuni.cz Poslední úprava: Kotáb Petr, JUDr., Ph.D. (10.09.2024)
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Introduction Tax treaties Scope and definitions Permanent establishment Allocation of taxation rights I Allocation of taxation rights II Allocation of taxation rights III Methods of elimination of double taxation Special provisions Wrap-up and practical excercises Poslední úprava: Sojka Miroslav, Mgr. (25.06.2024)
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Mandatory: 1) Presentation outlines for individual lectures 2) OECD Model Convention with Respect to Taxes on Income and on Capital 2017 3) Particular Bilateral Conventions on Elimination of Double Taxation will be distributed electronically during the course Recommended: 4) OECD Commentaries on the Articles of the Model Tax Convention 5) Vienna Convention on the Law of Treaties 1969
Poslední úprava: Sojka Miroslav, Mgr. (25.06.2024)
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Students are recommended to have passed a general course of Public International Law at any university. Poslední úprava: Sojka Miroslav, Mgr. (25.06.2024)
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