Koncept skutečného vlastníka ve světle české a EU daňové judikatury

This thesis examines the concept of beneficial owner in Czech and European tax case law within the context of international double taxation treaties. The aim of the thesis is to analyse the evolution of this concept in judicial practice and to assess its impact on the level of legal certainty for tax entities in the Czech Republic. The theoretical part addresses the development of the concept from the OECD perspective through European and Czech legislation, mapping the emergence of terminological discrepancies. These discrepancies result in interpretive ambiguities and serve as the foundation for two distinct approaches to beneficial ownership: the legal and the economic. The practical part of the thesis analyses significant court decisions from the perspective of both interpretations. Based on this analysis of case law, the evolution of the judicial approach is described, including current practice. Finally, the thesis highlights the uncertainties in the interpretation of the term "beneficial owner" and proposes possible solutions to prevent such ambiguities.