| Abstract [eng] |
Harmonization of Profit Taxes in EU: Goals, Areas, Perspectives The master's thesis examines the concept of corporate tax and the main elements of taxation. Also, what steps have been taken at EU level in the field of corporate tax harmonization and further perspectives towards this tax harmonization. The work is divided into three parts. The first part analyzes the concept of income tax and the elements by describing the concepts of tax and profit separately. The main elements of the tax are also distinguished - the tax subject, the tax base and the tax rate. The impact of the avoidance of double taxation on corporate tax harmonization is also discussed. The second part examines the concept of tax harmonization and what legislation has been adopted to harmonize direct taxation. The types of harmonization were singled out and described in the work: external, internal, complete, partial, gradual, in one stage, positive, negative. It was also pointed out that tax harmonization takes place on the basis of directives. The EU has adopted several directives in the field of direct taxation. The most important of these are the Parent - Subsidiary Directive, the essence of which is to eliminate double taxation on distributed profits between parent companies and subsidiaries. Another directive is the Interest and Royalties Directive. The purpose of this Directive is to exempt from withholding tax where interest or royalties are paid by one associated undertaking to another. The last directive highlighted in the paper was the Merger Directive, which allows for the exemption from taxes arising from the reorganization of a multinational company. The third part of the work highlights tax competitiveness and further harmonization of corporate tax and its prospects. Tax competition has largely led to tax harmonization. This led to the draft Common Consolidated Corporate Tax Base presented by the EU Commission, which aims to establish new criteria for calculating corporate tax. According to the European Commission, the different tax systems of the Member States hinder the functioning of the internal market and the free movement of capital. However, Member States fear that such harmonization of the base will lead to future harmonization of tariffs at EU level, which would mean a complete loss of national sovereignty in the field of taxation. The author of the paper points out that the main obstacle to the harmonization of corporate tax will be the requirement of unanimity in the adoption of EU tax issues. According to the author, until the method of adoption is changed from unanimity to qualified majority, in this case the harmonization of corporate tax will not be achieved in the early future. |
