Архив статей журнала
Technological developments have fostered cross-border e-Commerce transactions. This study aims to reconstruct the concept of the meaning of physical presence in the criteria for identifying foreign individuals and foreign entities as permanent establishments. Reconstruction uses the terminology of physical presence, which is adjusted to the presence of a new post-pandemic order, namely maintaining distance in certain situations. The term maintaining distance is translated as the distance between foreign individuals, foreign entities, and service users. This study proposes a reconstruction of the concepts of physical presence, the subject of permanent establishments, and the objects of permanent establishments. The concept of Significant Economic Presence is relevant to the fulfilment of three criteria: revenue, digital, and user. The reconstruction of permanent establishments involves determining the digital and user aspects. Reconstruction of permanent establishments involves determining the digital aspect of income. This study proves the hypothesis that the addition of Significant Economic Presence criteria to the determination of permanent establishments in e-commerce transactions increases the fairness of taxation rights in the source country. Therefore, it is necessary to review the determination of permanent establishments, especially e-commerce transactions, which are not limited to a physical presence with a wider scope through revenue, digital, and user criteria. This study makes a theoretical contribution to the significance of economic presence by replacing the meaning of the physical presence of a permanent establishment. Thus, the potential for permanent establishment taxation is not limited to the potential value-added tax but can also be on the potential income tax.
The article deals with the evaluation of the impact of real estate tax reforms on their tax burden in the Czech Republic in the years 1993–2024. Real estate tax is one of the direct taxes, and in comparison, with income taxes, its importance lies mainly in providing income for local budgets. The unit type of tax rate specifically determines real estate rates. Facts, that tax reform in the area or real estate tax are minimal, the tax burden is often decreasing. As the tax burden decreases, so does the tax revenue. However, when tax reform occurs, this reform is often characterized by a significant increase in the tax burden. This is also evidenced by the last implemented tax reform in 2024 when rates increased by approximately 80%. The previous tax reform occurred in 2010 and increased rates by 100%. Despite this increase, the real tax burden decreased compared to the first analysed year 1993 and the last year 2024. The results of the regression analysis show that inflation is the factor that negatively affects tax revenue. To minimalize a decrease in tax revenue from 2024, a provision containing an inflation coefficient is implemented in the legislation as part of the 2024 reform. Conversely, a reduction in the tax burden was not found for real estate intended for permanent housing in small municipalities with up to 600 inhabitants. On the contrary, there was an increase in the tax burden. Scientific methods such as analysis and comparison, as well as regression and correlation analysis are used to achieve the paper’s goals.