Taxable income from employment of foreign employees

The subject of my diploma thesis is the taxation of income from dependent activities with a focus on the creation of "super-gross income" for foreign employees who participate in the foreign system of compulsory insurance schemes. From 1 January 2019, the income of these employees for the purposes of determining the tax base was increased by the amount of foreign compulsory insurance premiums. As the foreign insurance systems are very different, the effective tax rates to which posted employees in the Czech Republic are subject to are different as well. Based on the findings, it can be said that most foreign systems have a lower contributions rate and these posted employees will be subject to a lower effective tax rate than domestic taxpayers and at the same time this will have a negative impact on the state budget. In addition to the decline in tax revenue, this amendment caused great legal uncertainty on the part of tax subjects and implemented a foreign element into the domestic tax base, which creates additional administrative costs for tax subjects, and is also an element that the tax administrator is unable to competently verify.