Abstract

Th e decision of the British people to leave European Union (Brexit) will have signifi cant eff ects for the Polish taxpayers, who are economically or legally linked to UK. Th is article presents in the fi rst steps diff erent considered scenarios for the departure of the UK from the European Union. Subsequently the possible tax consequences in the Corporate Income Tax are discussed, in particular resulting from the fact that the Parent/Subsidiary Directive, Interest and Royalties Directive and the Merger Directive will cease to apply. Th e article analyses the potential changes in the taxation of the dividends, interest and royalties paid between the associated companies from UK and Poland, as well as taxation of the restructurings involving entities from UK (merger, division, exchange of shares). Th e author points out the structures within the corporate groups that may adversely aff ect the tax position of the Polish taxpayers aft er Brexit. It is recommended for the taxpayers to identify in advance those potentially harmful structures within their corporate groups and to consider implementing alternative solutions.