Dubious Taxable Status of Polish Tax Capital Groups

Abstract

The article analyses tax treaty entitlements of tax capital groups (TCGs). As a case study, Polish rules on TCGs are analysed together with a large large network (nearly 90) of the Poland's tax treaties, the OECD Commentary and relevant scholarship and jurisprudence. The content of the article is by analogy relevant - mutatis mutandis - to all other tax treaties and their interaction with domestic rules on TCGs.

The article was originally published at  Tax Notes Int’l, October 14, 2013.