Globální minimální sazba daně z příjmů právnických osob

The diploma thesis deals with the global minimum corporate income tax rate of 15%, which constitutes a new tax obligation for large multinational and domestic corporate groups. The main objective of the diploma thesis is to determine the impact of the introduction of a global minimum corporate income tax rate on a selected multinational corporate group. A sub-objective of the thesis is to identify potential low-tax jurisdictions in the European Union. The theoretical part of the thesis deals with the issue of profit shifting, the BEPS project and the rules introduced under the Pillar II initiative. The subsequent practical part of the thesis includes the identification of tax jurisdictions which, based on the development of effective corporate income tax rates, could be considered as low-tax jurisdictions, and the application of Pillar II rules to a selected multinational corporate group, including a comparison of the group’s effective taxation before and after the introduction of the Global Anti-Base Erosion Rules (GloBE rules).