Abstract
Taxation of international groups of companies can be based on two models: These are: 1) unitary taxation, whichinvolves determining the income of the group as a whole and then dividing it between individual companies, 2)separate entity taxation, which involves each entity being taken into account separately and its income beingdetermined as if it were an independent entity. In practice, it was decided to choose separate entity taxation, whichresulted in legislation on transfer pricing. However, using this model did not protect against tax optimization usedby international groups of companies, which prompted the OECD and the EU to take various actions to combat it.The latest initiative in the area of taxation of international groups of companies is the global minimum tax model.Its essence comes down to charging an additional amount of tax if the effective tax rate in a given tax jurisdictionis lower than 15%. In Poland, this model has not yet been implemented, it will most likely happen from 2025, hencethe lack of practical experience with its application
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