Transformacja podatkowych regulacji prawa holdingowego w Polsce
Transformation of tax adjustment of holding law in Poland

Summary/Abstract: Due to the most often international nature of capital and personal relations, tax status of groups of related companies is determined by the provisions of the European Union, member states and international treaties. These regulations define the status quo between the aspirations for the protection of national fiscal interests and the harmonization of the laws of the member states towards reducing barriers to the free movement of goods, services and capital. The progress of work on the final version of the Council directive on a community consolidated corporate tax base, suggests that the major community entrepreneurs − usually operating under the variously related groups of companies − in the near future should expect a significant tax revaluation of realities of shaping economic efficiency. At the same time, upon the recognition by the Polish parliament the resolution dated 13.05.2011 of the project of indicated above directive as contrary to the fundamental principles of the EU, there is a need for a hierarchy of juridical principles of the Treaty and the need to consider the social-economic merits of binding regulations, strengthening the competitiveness of EU business at the expense of cross-border fiscal autonomy violations of the Member States.

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