Abstract
The publication deals with the theoretical aspects of tax avoidance, which taxpayers achieve through controlled foreign companies. Tax avoidance in the field of income taxes involves a variety of taxpayers' actions, which can take place both within a country and internationally.
States usually respond to such taxpayers' actions with a number of measures in order to prevent a reduction in public budget revenues while ensuring fair and neutral taxation. Many of these measures have already been examined in detail.
They are subject of a number of Czech and foreign publications. This publication therefore examines the theoretical aspects of the controlled foreign company rules, which are a new institute within the legal order of the Czech Republic, and therefore only partial attention has been paid to it in the academic sphere in the Czech Republic.