Daňové plánování a změny struktur financování v návaznosti na BEPS

Křenek, D. Tax planning and changes of financing structures according BEPS. Diploma thesis. Brno: Mendel University, 2018. This doploma thesis deals with quantification of impact into companies tax bases, which are using tax planning related to intra group financing. Quantification is done before and after application BEPS rules. The thesis consists of two main parts. The first part contains a review of the literature, which defines mainly problematic of tax planning using intra group financing, basic tax structures, thin capitalisation rules, analysis of action plan number 4 BEPS and analysis of ATAD direction. The second part quantifies impacts into tax bases companies before and after implementation of ATAD