Daňové aspekty držby podílu mateřskou společností podle zákona o daních z příjmů

This thesis addresses the tax implications of a parent company's holding of a share in a subsidiary under Act No. 586/1992 Coll., on Income Tax. The aim of this thesis is to define what constitutes costs relating to the holding of a share in a subsidiary within the meaning of Section 25(1)(zk) of the Income Tax Act, and to identify situations in which the 5% rate of income from profit distributions paid by the subsidiary is applied as indirect (overhead) costs relating to such holding. The first part of the thesis defines fundamental concepts such as parent company and subsidiary. The following chapters describe the legislative development of the provision in Section 25(1)(zk) of the Income Tax Act and explain the specifics of direct and indirect (overhead) costs relating to the holding of a share in a subsidiary. The final part of the thesis analyses the case law of the Supreme Administrative Court relating to this issue.