Daňová konkurence v USA a v Evropské unii

The subject matter of the thesis is a comparative analysis of the possibilities of tax competition in the USA and in the European Union. It aims to compare the extent and form of the tax competition within these systems. The thesis consists of five parts. At the beginning, the term tax competition is examined and the possibility of a distinction between fair and unfair tax practices is explored. In the next part the analysis of the US tax system with a focus on competition in the area of direct and indirect taxation is carried out. The third part provides similarly structured analysis of the tax competition in the EU. The fourth part presents the evaluation and the comparison of the tax competition in both systems. The final part concludes with certain normative recommendations for the future of the EU tax system which are made with respect to their applicability for current deliberation of the reform of the taxation in the European Union. The performed analysis yielded interesting results. Contrary to the expectations, it was determined that the tax competition in the US was more intense than in the EU and the tax practices used by some US states included at least the same level of unfairness as those used by some member states in the EU.