Selected Tax Aspects of International Business

The result of the global integration of the world economy are globally operating corporations. Multinational enterprises operate in different countries whose economic policies are different from each other. These differences have considerable impact on tax policy. Taxes are the subject of conflicting interests of the international business and tax policy. One of the current objectives of the MNEs is to reduce the total cost in order to achieving competitive advantage in the global market as well as to minimize the global tax liability through its optimization. To achieve these objectives the international tax planning is a widely used means. International tax planning uses tax havens and their favourable tax conditions to divert profits. Minimizing tax liability often leads to tax avoidance or tax evasion. Different legislative adjustments and mutual meeting of local and international legislation gradually uncover gaps and weaknesses enabling reduction and shedding of profits. Consequently, states are deprived of significant tax revenue. One of the most common and most important methods to minimize the tax liability of MNEs is transfer pricing. Transfer prices are to be determined in accordance with the arm's length principle, using comparative analysis and an appropriate method of assessment. Transactions carried out between associated enterprises may be regarded as a risk area which gets to the fore states and tax administrations. The first part of thesis focuses on tax policy in terms of international taxation of income and international tax planning. The second part presents a transfer pricing. The third and last part describes the practices of MNEs in transfer pricing and corresponding initiatives of national and international organizations