Course detail
International Taxation of Incomes
FP-FitiPAcad. year: 2026/2027
The course focuses on the issues of international income taxation. Students are introduced to the concept of international double taxation and the tools used to mitigate it. Attention is also partially given to legislation at the European Union level and to emerging trends in the field of international income taxation.
Language of instruction
Number of ECTS credits
Assignment to study programme types
Mode of study
Guarantor
Offered to foreign students
Entry knowledge
Knowledge of the basic principles of income taxation for individuals and legal entities.
Rules for evaluation and completion of the course
Examination Requirements: Knowledge of the covered material and its practical application.
The course is concluded with a written exam. The test includes a problem-solving section and open-ended questions aimed at assessing the understanding of key concepts, etc.
The maximum score is 20 points (test duration: 75 minutes).
To pass the exam, students must obtain at least 50% of the possible points.
The exam is graded according to the ECTS scale.
Students with an Individual Study Plan (ISP):
The same rules for course completion apply to students with an ISP. The exam date is set in accordance with the regulations specified in the approved ISP.
Aims
Within the course, students will:
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Acquire theoretical foundations and practical skills in the field of international income taxation.
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Understand the principles of international income taxation and the specific rules contained in double taxation treaties.
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Gain knowledge of the rules of international income taxation and the obligations of taxpayers.
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Be able to identify the tax obligations of residents and non-residents and to interpret and apply the basic norms of international income taxation contained in double taxation treaties.
Study aids
Prerequisites and corequisites
Basic literature
LANG, Michael. Introduction to the law of double taxation conventions. Amsterdam: IBFD, 2010, 222 p. 1st edition. ISBN 90-872-2082-0.
OECD (2019), Model Tax Convention on Income and on Capital 2017 (Full Version), OECD Publishing, Paris, https://doi.org/10.1787/g2g972ee-en.
Recommended reading
Lang, Michael, et al. Introduction to European Tax Law on Direct Taxation. 8th ed. London: Spiramus Press, 2025. ISBN 9781913507770.
Classification of course in study plans
Type of course unit
Lecture
Teacher / Lecturer
Syllabus
2. Double tax treaties (essence, objects, model treaties, structure of the treaties, scope, princip of conditional application priority).
3. Tax residency and its determination, tax residents and taxation of their incomes (in general), tax non-residents and taxation of their incomes (in general), conversion of currency.
4. Taxation of incomes of tax non-residents from the sources in the Czech Republic (duties of payers, duties of tax-payers, possibilities of tax optimization for tax non-residents of the Czech Republic compared to tax residents of the Czech Republic).
5. Rules for taxation of selected incomes as stated in double tax treaties – incomes from immovable property, capital gains, incomes from employment
6. Rules for taxation of selected incomes as stated in double tax treaties – director´s fees, enternainers and sportspersons, pensions.
7. Rules for taxation of selected incomes as stated in double tax treaties – taxation of business profits.
8. Rules for taxation of selected incomes as stated in double tax treaties – dividends, interest and royalties.
9. Taxation of tax residents – methods for avoidance of double taxation (description, principles, Article 38f of Act on Income Taxes).
10. Taxation of tax residents – application of methods for avoidance of double taxation.
11. Introduction to European tax law in direct taxes.
12. Reflexion of EU direct tax law in Czech tax acts.
13. European Court of Justice case law in international taxation of incomes.
Individual preparation for an ending of the course
Teacher / Lecturer