WYBRANE PROBLEMY ZWIĄZANE Z OBOWIĄZYWANIEM ZWOLNIENIA Z MINIMALNEGO PODATKU DOCHODOWEGO OD OSÓB PRAWNYCH DLA MIĘDZYNARODOWYCH GRUP SPÓŁEK W KONTEKŚCIE PRZECIWDZIAŁANIA WYSTĘPOWANIA LUKI CIT
SELECTED PROBLEMS RELATED TO THE APPLICABILITY OF THE MINIMUM CORPORATE INCOME TAX EXEMPTION FOR INTERNATIONAL GROUPS OF COMPANIES IN THE CONTEXT OF COUNTERACTING THE CIT GAP

Summary/Abstract: The research problem undertaken by the author is an exemption from minimum tax for groups of entities in which there is a non-resident. The reason for taking up the research topic was the research gap in this area. Based on tax rulings and the literature on the subject and the standpoint of the Ministry of Finance, the motives for introducing the minimum tax and the exemption for groups of entities, the way the exemption functions, as well as the reasons for its change and the mutual relationship between the exemption and the ratio legis of the minimum tax were analysed. As a result of the analysis, it was confirmed that there was a significant discrepancy between the normative solutions and their interpretation by tax authorities and the purpose of introducing the minimum tax.

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