Daňové dopady fúzí a přeměn v obchodních korporacích v ČR

This master's thesis examines the tax implications of corporate transformations in the Czech Republic, with a particular focus on corporate income tax. The aim of the thesis is to analyse the current legal framework governing corporate transformations at both the European and Czech levels and to systematically identify the tax consequences associated with individual forms of transformations, namely mergers, demergers, transfer of assets to a shareholder, and changes of legal form. The thesis provides a detailed discussion of key tax concepts, including the effective date of transformation and its impact on taxable periods, tax depreciation, the transfer of tax losses, valuation differences and goodwill, provisions and allowances, tax advances, and the implications of corporate transformations in the areas of value added tax, real estate tax, and road tax. The theoretical findings are verified through three model case studies based on fictional data from medium-sized construction companies, illustrating a merger by acquisition, a demerger through spin-off with the formation of a new company, and a transfer of assets to a shareholder. The thesis concludes that the fundamental principle underlying the entire area of corporate transformations is the principle of tax neutrality, the practical application of which requires a thorough understanding of legal regulations and interpretative guidance issued by the tax authorities.