Abstract

The aim of the CFC regulations is to prevent tax avoidance which could potentially arise in case foreign entities controlled by Polish taxpayers are taxed on beneficial terms comparing to those applicable in Poland. By including the foreign tax capital groups and entities from said tax capital groups in the scope of CFC regulations from 1 January 2019, the Polish legislator created various tax uncertainties for the Polish taxpayers. The aim of this article is to identify said issues and other practical problems for Polish taxpayers controlling entities from foreign tax capital groups.