Směrnice o úsporách 2003/48/EEC a její aplikační problémy

Taxation Directive represents current effort of the European Union to tackle tax evasion on its territory. Therefore, primary purpose of the thesis is to assess practical effectiveness of the directive in question. Comprehensive analysis begins with the theoretical part that thoroughly describes mechanisms on which directive is based and reflects on the theoretical principles of international taxation. Considerable attention is also paid to the historical formation and development of the efforts of the EU to prevent tax evasion. Critical evaluation of the real economic effects of the directive brings relatively clear conclusion about its low effectiveness. However, undertaken comparative legal analysis of the implementation of the directive shows that insufficient practical results are not caused by the improper transposition. Rather deficiencies consist in imperfect definition of the subject-matter of the directive. Thesis concludes with the study of the most important application problems and critically assesses the possibilities of their solution.