Holding company location: a Polish tax perspective

This paper aims to present the size and structure of passive income payments, such as dividends, interest, royalty fees for intangible services, made by companies domiciled in Poland belonging a multinational enterprises (MNE) group. The authors formulate hypothesis that tax jurisdictions offering extensive legal incentives holding structures, particular concerning treatment dividends other withholding are preferred location companies. A review literature sources precedes empirical research. analysis shows flows, including royalties, which constitute dominant type payments companies, directed from primarily countries with regulatory solutions friendly so-called intra-EU havens, namely Luxembourg, Cyprus, Netherlands, Malta Ireland. Real trade these is neither significant nor proportional scale income.