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Termination of the legal existence of the tax capital group – results in proceedings before tax authorities and administrative courts


Zyskowska, Renata



Subject and Keywords:

tax capital group   Corporate Income Tax   party   tax proceedings   court and administrative proceedings


Tax capital group concept has been present in the Polish tax system for over 20 years. Provisions related to the rights and obligation of the tax capital group as the taxpayer in the corporate income tax were reviewed several times. Continuing economic development forced the Polish legislator to provide appropriate solutions enabling this group of taxpayers to fulfill their tax obligations in a manner that takes into account the specificity of their structure and functioning. Despite multiple changes introduces in this regulations, the issues that require, in the author'sopinion, an immediate response from the Polish legislator, remain in doubt. The subject of this article is an analysis of the provisions of general and specific tax law from the perspective of the possibility of enforcing rights by a tax capital group in proceedings before tax authorities and in court and administrative proceedings. The intention is to identify gaps in the law regarding the tax and legal situation of the tax capital group after the end of its legal existence. The study will be conducted in the context of judicial and administrative judgments. The study will be completed with conclusions de lege lata and postulates de lege ferenda.


Uniwersytet Wrocławski. Wydział Prawa, Administracji i Ekonomii


Miemiec, Wiesława. Red.

Date issued:



ISSN 2544-8382






Kwartalnik Prawno-Finansowy, ISSN 2544-8382 ; nr 4/2019, s.78-99

Is part of:

Kwartalnik Prawno-Finansowy

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