IDEAS home Printed from https://ideas.repec.org/a/ipf/finteo/v38y2014i4p465-487.html
   My bibliography  Save this article

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

Author

Listed:
  • Magdalena MaÅ‚gorzata Hybka

    (Poznan University of Economics, Department of Public Finance, Poznań, Poland)

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.

Suggested Citation

  • Magdalena MaÅ‚gorzata Hybka, 2014. "Legislative proposal for a controlled foreign companies regime in Poland from an international perspective," Financial Theory and Practice, Institute of Public Finance, vol. 38(4), pages 465-487.
    • Handle: RePEc:ipf:finteo:v:38:y:2014:i:4:p:465-487
    as

    Download full text from publisher

    File URL: http://fintp.ijf.hr/upload/files/ftp/2014/4/hybka1.pdf
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. Egger, Peter & Wamser, Georg, 2011. "The Impact of Controlled Foreign Company Legislation on Real Investments Abroad: A Two-dimensional Regression Discontinuity Des," CEPR Discussion Papers 8460, C.E.P.R. Discussion Papers.
    2. Marsha Blumenthal & Joel Slemrod, 1995. "The compliance cost of taxing foreign-source income: Its magnitude, determinants, and policy implications," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 2(1), pages 37-53, February.
    3. Keller, Sara & Schanz, Deborah, 2013. "Measuring tax attractiveness across countries," arqus Discussion Papers in Quantitative Tax Research 143, arqus - Arbeitskreis Quantitative Steuerlehre.
    Full references (including those not matched with items on IDEAS)

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Das-Gupta, Arindam, 2004. "The Income tax compliance cost of corporations in India, 2000-01," Working Papers 04/8, National Institute of Public Finance and Policy.
    2. Matthias Mors & Anne Bucher & Katri Kosonen & Philippe Cattoir & Wim Koevoets & Werner Vanborren, 2004. "European Tax Survey," Taxation Papers 3, Directorate General Taxation and Customs Union, European Commission, revised Nov 2004.
    3. Jarle Møen & Dirk Schindler & Guttorm Schjelderup & Julia Tropina, 2011. "International Debt Shifting: Do Multinationals Shift Internal or External Debt?," Working Paper Series of the Department of Economics, University of Konstanz 2011-40, Department of Economics, University of Konstanz.
    4. Stamatopoulos, Ioannis & Hadjidema, Stamatina & Eleftheriou, Konstantinos, 2016. "Corporate Income Tax Compliance Costs and their Determinants: Evidence from Greece," MPRA Paper 75736, University Library of Munich, Germany.
    5. repec:npf:wpaper:08 is not listed on IDEAS
    6. Sascha O. Becker & Peter H. Egger & Maximilian von Ehrlich, 2013. "Absorptive Capacity and the Growth and Investment Effects of Regional Transfers: A Regression Discontinuity Design with Heterogeneous Treatment Effects," American Economic Journal: Economic Policy, American Economic Association, vol. 5(4), pages 29-77, November.
    7. Mardan, Mohammed & Haufler, Andreas & Schindler, Dirk, 2014. "An Economic Rationale for Controlled-Foreign-Corporation Rules," VfS Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100405, Verein für Socialpolitik / German Economic Association.
    8. Cozmei Catalina & Serban Elena Claudia, 2015. "The Influence Of Competitiveness On Investment Location Decisions –Case Study: France, Italy, Romania, Great Britain," Annals - Economy Series, Constantin Brancusi University, Faculty of Economics, vol. 2, pages 188-196, April.
    9. Deborah Schanz & Andreas Dinkel & Sara Keller, 2017. "Tax attractiveness and the location of German-controlled subsidiaries," Review of Managerial Science, Springer, vol. 11(1), pages 251-297, January.
    10. Michael Devereux, 2004. "Debating Proposed Reforms of the Taxation of Corporate Income in the European Union," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 11(1), pages 71-89, January.
    11. Verwaal, Ernst & Donkers, Bas, 2003. "Customs-Related Transaction Costs, Firm Size and International Trade Intensity," Small Business Economics, Springer, vol. 21(3), pages 257-271, November.
    12. Keller, Sara & Schanz, Deborah, 2013. "Tax attractiveness and the location of German-controlled subsidiaries," arqus Discussion Papers in Quantitative Tax Research 142, arqus - Arbeitskreis Quantitative Steuerlehre.
    13. Homburg, Stefan, 2000. "Perspektiven der internationalen Unternehmensbesteuerung," EconStor Open Access Articles and Book Chapters, ZBW - Leibniz Information Centre for Economics, pages 9-61.
    14. Dinkel, Andreas & Schanz, Deborah, 2015. "Tax attractiveness and the location of patents," arqus Discussion Papers in Quantitative Tax Research 188, arqus - Arbeitskreis Quantitative Steuerlehre.
    15. Schanz, Deborah & Feller, Anna, 2014. "Wieso Deutschland (fast) keine BEPS-Bekämpfung braucht," arqus Discussion Papers in Quantitative Tax Research 171, arqus - Arbeitskreis Quantitative Steuerlehre.
    16. Dinkel, Andreas, 2015. "Tax attractiveness and the allocation of risk within multinationals," arqus Discussion Papers in Quantitative Tax Research 189, arqus - Arbeitskreis Quantitative Steuerlehre.
    17. Petutschnig, Matthias, 2017. "Future orientation and taxes: Evidence from big data," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 29(C), pages 14-31.
    18. repec:ind:nipfwp:08 is not listed on IDEAS
    19. Sebastian Eichfelder & François Vaillancourt, 2014. "Tax Compliance Costs: A Review of Cost Burdens and Cost Structures," Hacienda Pública Española / Review of Public Economics, IEF, vol. 210(3), pages 111-148, September.
    20. Elemes, Anastasios & Blaylock, Bradley & Spence, Crawford, 2021. "Tax-motivated profit shifting in big 4 networks: Evidence from Europe," Accounting, Organizations and Society, Elsevier, vol. 95(C).
    21. Seidel, Tobias & von Ehrlich, Maximilian, 2014. "The persistent effects of regional policy - Evidence from the West-German Zonenrandgebiet," VfS Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100515, Verein für Socialpolitik / German Economic Association.
    22. James R. Hines, Jr., 1996. "Tax Policy and the Activities of Multinational Corporations," NBER Working Papers 5589, National Bureau of Economic Research, Inc.

    More about this item

    Keywords

    controlled foreign company; tax avoidance; Poland;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:ipf:finteo:v:38:y:2014:i:4:p:465-487. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Martina Fabris (email available below). General contact details of provider: https://edirc.repec.org/data/ijfffhr.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.