Legislative proposal for a controlled foreign companies regime in Poland from an international perspective

Abstract

Tackling corporate profit shifting requires appropriate anti-avoidance measures. This article reviews one of these measures, a controlled foreign companies (corporations) regime. It has been implemented in many countries, in some of them as early as the 1960s. The need for its introduction has also been expressed on many occasions by the Polish legislator. The article is composed of three sections. The first considers the reasons for the implementation of the analyzed regime. The second describes the controlled foreign corporation legislation in the USA and selected European Union member states. The last section is devoted to a bill on taxing controlled foreign companies in Poland.