H25 - Business Taxes and Subsidies including sales and value-added (VAT)Return

Sweetened beverages are a significant source of added sugar in the diet and thus a major risk factor for obesity and serious diseases with significant societal costs. In order to curb their consumption, special excise duties have been imposed on them in a number of countries around the world. The aim of our research was to test the effectiveness of a tax on sweetened beverages using real data on the global prevalence of type 2 diabetes. We tested a relationship between diabetes prevalence and the tax assuming that the prevalence of the disease depends on the income of the country. Our analysis revealed a statistically significant, but contrary to expectations, positive relationship between disease prevalence and the existence of tax in richer countries. This suggests that the tax on sweetened beverages is not high enough to make demand price elastic, or that we need to wait a longer time before the tax is effective, or that the decline in diabetes prevalence is not yet large enough?

The paper deals with Czech and Slovak budget policy during the covid-19 pandemic. Due to extensive expansionary measures implemented as part of the budget policy, the Czech and Slovak public finances were disrupted. Deviations in the implementation of the Czech and Slovak state budgets are assessed using a combination of actual values and own forecasts based on SARIMA-based econometric models applied to the 2010–2020 time series. The main goal of the text is to determine the overall impact of the covid-19 pandemic on the management of the Czech and Slovak state budgets caused by increasing public expenditures and a decrease in public revenues. Special attention is paid to the related additional expenses and reduced budget revenues. The results of the most suitable models are used as input data for the autonomous development of the state budgets of the Slovak Republic and the Czech Republic without the influence of the covid-19 pandemic.

The article focuses on the reasons for the adoption and implementation of the ATAD. The main objective of the article is then to analyse the impact of this directive on corporate tax revenues in the European Union. The analysis was conducted using the statistical method of the test of the consistency of means, which is a method that allows two samples to be compared with each other, and the years examined were 2018 and 2021. For the international comparison of corporate tax revenues, two indicators are used, namely the corporate tax quota and the share of corporate tax on total tax revenues, and both of these indicators were used for the analysis. In the case of the test carried out using the corporate tax quota indicator, the impact of the introduction of the ATAD on corporate tax revenues in the EU was not demonstrated. The test using the indicator for the share of corporate tax in total tax revenue also failed to show an effect of the introduction of ATAD on EU corporate tax revenue. Using the statistical method of the test of the consistency of means, the effect of ATAD on EU corporate tax revenue was not proven.

The article presents the system of indicators for evaluation of taxation of international companies active in the Czech Republic. Based on the identification of the potential channels of corporate tax base erosion and profit shifting of multinational enterprises it enables to recognize companies whose taxation policy might not be in line with the best practice. Extreme values of the indicators might initiate further examination of a company by state authorities. This research thus complements the existing set of analytical tools of the government agencies and research institutions in the area of taxation of multinational enterprises.

All transactions in multinational enterprises which are realized among group members are very sensitive to tax risks arising from (appropriate) asset valuation. The more often the transactions are connected to intangible assets or R&D services the more tax risks they generate. This article identifies theoretical and then practical issues while stating license fees or intangible asset valuation. The authors show how it is possible to use purpose-built model of license fees for optimizing tax position of each group member, especially of the member who develops specific intangible asset. The authors compare the old version of OECD Transfer pricing for MNEs Guidelines in mentioned field with the proposed version, too.

Major part of multinational companies from the whole world is facing the problems connected with the valuation of goods in the international business. Transactions between related parties are subject to examination guided with different rules and contradictory interests of both customs and fiscal authorities. This article makes an attempt to describe basic problems and propose some resolution which should be in the interest of all concerned.

The contribution deals with the role of the branch standards in the process of the optimizing of the capital structure of the concrete firm. The enterprises can use the branch standards available and adjust their indebtedness on this level besides the process of the active optimizing. The problem however lies in the identification of these branch standards. The branch standards in the seventeenth areas were analyzed from the point of view of the Czech Republic, the U.S.A., of the world and of the Europe. Even if the results in the single areas were different, it is possible to generalize that the indebtedness of the firms in the Czech Republic is in general higher than it is in the U.S.A., in Europe, and in total in the world. The reason could lie in the relatively great benevolence in the area of the offers of the bank loans in previous periods. The next interesting conclusion arises from the findings out that the indebtedness from the market values is lesser than from the accounting values, which demonstrates the higher market value than the accounting value. The maximum values were recommended for the indebtedness of the enterprises in the Czech Republic on the basis of the above mentioned data. The procedure of the solution was identified in three groups according to the differences in the single values of indebtedness in the concrete spheres.

The article focuses on trends in tax revenue from corporate income tax in the Czech Republic, the development of number of taxpayers; corporate profits tax bases and the interactions between them. It also shows impacts of profit adjustments on corporate tax revenues. The results of the analysis show that it is difficult to explain the variation in the tax base or tax revenue only by one variable, such as the development of the economy, the number of taxpayers and the tax and accounting rules. Dependency between the tax obligation and the number of taxpayers or the tax rate was not confirmed. Only weak dependency exists between changes in GDP and changes in tax, mainly due to fluctuations in taxes in the first half of the nineties of the last century; in the last decade the dependency is stronger. Relatively strong is the relationship between accounting profit of firms and GDP, especially in the last 15 years. For the calculation of the tax base more important than firms profits are changes of profits to tax base and this effect during the economic slowdown increased.

The paper tries to deepen the understanding of transfer prices determination in both transnational companies and intra-national business relations. It deals with the process of transfer prices formation within intra-group financing. The author focuses mainly on inferring the methodical principles from the general theory. The obtained principles are then confronted with the Czech legislative environment. After specifying the method of common interest rate formation, the author draws reader's attention to the factual impact of a thin capitalization test on arm's length interests based evaluation forming.

This article based on comparative analysis investigates the effective average tax rates of corporations determining an actual tax burden in EU Member states with the emphasis on the Czech Republic and further the individual effective rates calculated by various methods. However corporations are taxed by one nominal rate, in fact the different sectors and types of investments are taxed at different rates. Such taxes having distorting effects on the behavior of economic entity are considered to be wrongful and ineffective because they cause excessive tax burden. The current Tax Reforms put a target to limit these looses caused by distortions. There are several specific effective rates,which vary each other inmethodology of calculation. Devereux et al. 2008 figured out average (EATR) and marginal (EMTR) rates using by the European Commission and Eurostat for their statistics. These are microeconomic indicators ex ante whereas implicit rate (ITR) is computed as ex post macroeconomic indicator.

The aim of this contribution is to analyze the influence of taxes on the financial management and decision of enterprise. The enterprise could be influenced in a passive or active way. In a passive way the company has to bear some negative tax consequences or on the contrary could exploit positive tax consequences. In a active way the company could exploit taxes for the decision concerning some concrete option with the aim to maximize the market value of the enterprise or to fulfill the other corporate aims. The most important role plays the income tax, which could influence the choice concerning the appropriate legal form of business, investment decision, risk of business and the options of financing of corporate. Value added tax could influence mainly cash flow of the enterprise if the company is the payer of this tax. Excise taxes and ecological taxes could influence negatively the competitiveness of the company mainly if these taxes are lesser in neighboring countries. Property taxes plays marginal role. The most important role plays also the mutual interaction of state and the firm sphere mainly in the case of tax deductable costs, deductible items or tax rebate.

All transactions in multinational enterprises which are realized among group members are very sensitive to tax risks. The more often the transactions are connected to intangible assets or R&D services the more tax risks they generate. This article identifies theoretical and practical problems of services level agreements (SLA) in financial management. The author offers step-solutions for utility measurement by service provider and service receiver, cost allocations and deals with suitable profit level indicators. The goal of this article is to provide sufficient analysis of arm's length principle in SLAs with respect to the OECD Transfer pricing for MNEs Guidelines and with respect to other significant regulations.

Cost contribution arrangements (CCAs) and Cost sharing agreements (CCAs) belong to the tools of modern finance management. Costs spent by associated enterprises on developing, producing or obtaining assets, services or rights (in general - benefits) are used for tax optimizing too. The main purpose of joint research and development, producing or obtaining benefits is to lower these costs as much as possible or to maximize the benefits. The problematic of transfer pricing and arm´s length principle in connection to CCAs, CSAs is mentioned in this article, too. Next, there is mentioned how to settle participation shares of the total cost and benefits contributions with respect to the OECD Transfer pricing for MNEs Guidelines and with respect to other significant regulations.

The article is focused on the present situation of property tax in the tax system of the Czech Republic in the context of the European Union and in their expected development. It analyses advancement of tax revenues of several property taxes, their importance in several levels of public budgets, role of real estate tax from the point of view of fiscal decentralization. It assesses the present situation of recurrent taxes on immovable property and modification proposed in taxation of farm land and possible impact on local budgets. The question of justification of their further existence in the Czech tax system is considered at transfer taxes and their possible relationship with income tax and real estate tax. Expected impact of prepared EU directive on motor vehicle taxation in Czech Republic is analyzed at the end of the article.