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EN
All MNEs generate their revenues through a business model which have a certain organization of functions performed, assets used and risks assumed. Nevertheless, the changes in economic environment have resulted into the situation, when all governments have been increasingly focused on raising revenues through taxation and conversely many MNEs have been focused on decreasing of their taxable business income with using various means. One possibility how to achieve it for both sides is a transfer pricing. The aim of the paper is to create a general model, under which the MNEs could decide for the best business model within the frame of the tax planning, but which would also enable to quantify the impacts on the state budget resulting from that tax planning strategy. Furthermore, the general model determinates more accurate arm's length transfer prices in the business model with respect to recommendations in OECD TP Guidelines, particularly functional and comparability analysis.
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Ograniczenie obciazen podatkowych w Polsce

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EN
The purpose of this paper is to analyze the possibilities and implications of reducing the income tax burden for the Polish economy. Two major proposals are presented: 1) halving the tax-GDP ratio to below 20% and changing the structure of budget expenses to reflect the real needs of the society (e.g. public order and safety, education, R&D, health, infrastructure); and 2) reducing, and finally abolishing income taxes to positively influence economic growth and welfare in Poland. Several implications on the conduct of these proposals are discussed. Paper findings are subject to a discussion concerning the flat tax debate.
EN
Formation of a single market is one of the main priorities during the integration process of the European Union. For this purpose it was planned to unify tax rules throughout the entire Community. The main question of this paper is whether the European Union has been meeting the objective of single market. It focuses on a question whether the tax systems are converging in the context of tax burden, tax mixes and implicit tax rates. Beta and Sigma convergences are used for meeting the goal of the paper. The results suggest evidence of a convergence in the field of tax burden and implicit tax rates during the analysed period. The results also highlight the fact of a possible influence of EU integration as well as of globalization and tax competition issues.
EN
The paper determines absolute and relative values of tax burden dissociation imposed on cigarettes in the Czech Republic and Slovakia based on analysis of average weighted prices of cigarettes in the years 2004 - 2009. Essential is comparing of calculated prices and tax burden imposed on cigarettes in given price level before and after tax burden change. The identification of determinants which affect tax shift measure and factors which affect calculated outcomes is important. The methods of measuring tax incidence including its outcomes in this paper are also described. This makes possible to set the common results about shifts of increased tax burden imposed on cigarettes in specific conditions in the Czech Republic and Slovakia including their comparison with theoretical and practical observations in given area.
EN
The issue of tax harmonization and tax competition in the European Union has dealt extensively since its inception. The aim of this study has been find out dependence between tax competition and tax burden in European Union by regression analysis and to analyse chosen reasons for tax competition in area of direct taxes. We have confirmed by regression analysis and correlation following: tax competition is connected with lower government expenses in public services, it leads to higher economic growth, it raises tax burden of consumptions and budget deficit acts as limiting factor of tax competition.
EN
The article determines the transfer rate of tax burden to the buyers of agricultural products and food consumer in the most recent major change in reduced rates of value added tax in the Czech Republic in the late 2007 and 2008 and Slovakia since May 2004. At the same time it identifies the size of portion of increased tax burden which agricultural producers and sellers of food carry, after the increase in the reduced rate of value added tax in the Czech Republic and Slovakia. Possible future changes in this field are considered on the basis of determining the values of the distribution of increased tax burden. It also includes determination of indicator of change in the selling prices of agricultural products and food in the increase in the reduced rate of value added tax in the Czech Republic and Slovakia.
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