| Abstract [eng] |
Double Taxation Dispute Resolution Procedure in the EU The master's thesis mainly analyzes the double taxation dispute settlement procedures in the European Union by the legal acts of the European Union. Double Taxation Convention - Adjustment of Profits of Associates and Council Directive 2017/1852 on tax dispute settlement mechanisms in the European Union. The work aims to reveal the complexity and problems of double taxation dispute resolution mechanisms, to single out individual problems. Since Directive 2017/1852 is, in principle, implemented to eliminate the shortcomings and problems of double taxation dispute settlement procedures, it is analyzed whether the Directive eliminates the shortcomings. This master's thesis also mentions the development of double taxation dispute resolution, the concept of double taxation according to the legal acts of the European Union. The double taxation dispute settlement procedure is also described in detail, with its stages, initiation, and decisions. The third part of the paper describes the shortcomings and problems of double taxation dispute settlement procedures, both the mechanisms that existed before Directive 2017/1852 and the shortcomings reflected in the new Directive. Because of the problems and shortcomings identified in the third part of the preamble, this leads to the conclusion that the elimination of problems and shortcomings in double taxation dispute resolution procedures was necessary due to the lack of double taxation burden, disproportionate length of proceedings and the result obtained was not binding, the competent authorities were merely seeking a solution to the dispute. |
