One of the ways of countering tax avoidance is investigating and examining of taxpayers’ activities from the perspective of their economic substance. This can be achieved through judicial doctrines comprising the element ...

An important challenge of the modern tax law is efficient countering of tax avoidance. One of the ways of tackling this problem is investigating and examining of taxpayers’ activities from the perspective of their economic ...

As part of this publication, the key issue of legal protection of taxpayers avoiding taxation are analyzed. This issue is analyzed especially in the context of the in dubio pro tributario principle, construction (systemic) ...

The author analyzes the jurisprudence of administrative courts regarding a foreign controlled company. These judgments were made in cases related to complaints about individual interpretations of tax law provisions. He ...

Map of the tax gap in corporate income tax In highly developed countries, the programs of measuring tax gap have been successfully implemented since the seventies of XX century. In the case of corporate income tax, estimation ...

The article concentrates upon the issue of economic substance and its meaning for the ta Xsystem. In particular the aim of the article is to determine how the concept of economic substance is used in the tax systems of ...

The aim of this article is to demonstrate different ways in which the concept of economic substance is used on an international basis. From that perspective the outcomes of the BEPS project were firstly examined. Another ...

The purpose of the article is to determine the temporary scope of application of the provisions of the general anti-avoidance rule (GAAR) with regard to income taxes. It has to be determined when – as for income taxes – ...

The article argues that under Article 15 Section 1 of the Act of 15 February 1992 on corporate income tax an expense (cost) can be tax deductible only if it meets the criterion of purpose, understood subjectively, i.e. ...