EN
According to the author basis of a consideration is the Council’s Directive 2011/96/EU of 30th November 2011 on the Common System of Taxation applicable in the Case of Parent Companies and Subsidiaries of Different Member States. According to its rules, it is important that both a parent company and a subsidiary one have registered offices for tax purposes in different Member States. Another crucial thing is the avoidance of double taxation in an economic meaning regarding income pay out to the parent company by the one. Furthermore Article 5 of the above-mentioned directive states a principle, according to which a profit paid to a parent company by a subsidiary one is exempt from tax deducted with regard to a source of a revenue. Article 5 fulfills the assumption that double taxation in a legal meaning ought to be eliminated.