This article demonstrates that after the seemingly incorrect implementation of Articles 7–8 of the ATAD, the Polish CFC rules have become blatantly incompatible with the free movement of capital to the extent of their application to companies from third countries (the Polish black list). This study, moreover, confirms the thesis that the incompatibility of the Polish CFC rules was most likely caused by two elements of the ATAD: (1) minimum level of protection in Article 3; and (2) the option under Article 7(1)(a) which leaves the decision regarding the exemption from taxation of the CFC’s income if a CFC is established outside the EU/EEA and carries on a substantive genuine business activity there to Member States themselves. The analysis a...
Directives and their implementation into our legal system as well as case-law of the European Court ...
Nationalization and political and economic changes implemented after the II World War have never el...
This article deals with the problems of taxation of controlled foreign companies (hereinafter: CFC) ...
This article demonstrates that tax avoidance via controlled foreign companies (CFCs) established in ...
Tackling corporate profit shifting requires appropriate anti-avoidance measures. This article review...
1 Theoretical aspects of tax avoidance in the field of income taxes Abstract in English The disserta...
Celem niniejszej pracy jest kompleksowe omówienie problematyki regulacji dotyczących opodatkowania z...
Celem niniejszej pracy magisterskiej jest przybliżenie zjawiska unikania opodatkowania CIT, idącej z...
With effect from 1 January 2014, the Polish Parliament introduced amendments to the Polish Corporate...
Most states within the EU have some kind of CFC-legislation that allows the state in question to tax...
Capital and labor mobility facilitates cross-border activities of enterprises. In the era of...
Although direct taxation falls under the sovereignty of each individual Member State, that sovereign...
The act of nationalization as well as economic and political chaniges in functioning of State after...
CFC legislation has become an instrument to protect national tax bases and minimize the abusive effe...
peer reviewedOn July 16, 2016 the Economic and Financial Council of the European Union adopted the A...
Directives and their implementation into our legal system as well as case-law of the European Court ...
Nationalization and political and economic changes implemented after the II World War have never el...
This article deals with the problems of taxation of controlled foreign companies (hereinafter: CFC) ...
This article demonstrates that tax avoidance via controlled foreign companies (CFCs) established in ...
Tackling corporate profit shifting requires appropriate anti-avoidance measures. This article review...
1 Theoretical aspects of tax avoidance in the field of income taxes Abstract in English The disserta...
Celem niniejszej pracy jest kompleksowe omówienie problematyki regulacji dotyczących opodatkowania z...
Celem niniejszej pracy magisterskiej jest przybliżenie zjawiska unikania opodatkowania CIT, idącej z...
With effect from 1 January 2014, the Polish Parliament introduced amendments to the Polish Corporate...
Most states within the EU have some kind of CFC-legislation that allows the state in question to tax...
Capital and labor mobility facilitates cross-border activities of enterprises. In the era of...
Although direct taxation falls under the sovereignty of each individual Member State, that sovereign...
The act of nationalization as well as economic and political chaniges in functioning of State after...
CFC legislation has become an instrument to protect national tax bases and minimize the abusive effe...
peer reviewedOn July 16, 2016 the Economic and Financial Council of the European Union adopted the A...
Directives and their implementation into our legal system as well as case-law of the European Court ...
Nationalization and political and economic changes implemented after the II World War have never el...
This article deals with the problems of taxation of controlled foreign companies (hereinafter: CFC) ...