Daňová uznatelnost úroků v základu daně z příjmů právnických osob

The right to deduct interest from tax base, in comparison with the obligation to pay dividends from the profit after tax motivates companies to prefer debt to equity in the capital structure of the company, which, among other things, enables profit shifting to countries with lower tax rates. With the objective of preventing this behaviour, most of the developed countries introduced rules to limit tax-deductibility of interest. This diploma thesis analyzes the suitability of the Czech rules limiting the tax-deductibility of interest. It is structured into four chapters. The first chapter describes different approaches to the construction of the corporate tax base with regard to tax-deductibility of interest. The second chapter deals with the development and the current state of the rules limiting tax-deductibility of interest in the Czech Republic. In the third chapter, approaches of selected countries are analyzed and compared. Suitability of the Czech rules limiting tax-deductibility of interest is evaluated in the fourth chapter based on three criterions and recommendation for Czech tax policy are formulated.