Abstract

The article attempts to obtain an answer to the question of whether the amendment to the provisions of the Act of February 15, 1992, on corporate income tax (Consolidated text Journal of Laws of 2021 item 1800 as amended, hereinafter: ACIT) in the scope of the so-called indirect tax haven transactions referred to in article 11o paragraphs 1a and 1b ACIT, will affect the implementation of the goals for which it was implemented. The article indicates the purpose of the legal regulation introduced on 01/01/2021. Then the definition of the beneficial owner was presented. Subsequently, the analysis covered issues related to the obligation to exercise due diligence in transfer pricing. At the end, the so-called tax havens resulted from the regulation of the Minister of Finance of March 28, 2019, on the determination of countries and territories applying harmful tax competition in the field of corporate income tax (Journal of Laws of 2019 item 600) was compared with EU regulations in this area and with the document "Corporate Tax Haven Index - 2021 Results" developed by the Tax Justice Network. The article uses the dogmatic-legal method.