The Effects of Changes in Tax Rules Relating to Interest in Thin Capitalization

Abstract

The choice of funding the company’s capital is important from the point of view of tax planning because equity financing and financing of foreign capital have different tax consequences which have an impact on the profits generated by the company and budget revenues. Interest, unlike dividends, are the tax costs. Low equity of company compared to the size of debt, which derives from a shareholder, brings tax advantages both on the national and international levels. To reduce the erosion of the tax base through the free formation of the capital structure of companies, many countries have introduced special rules relating to thin capitalization. In Poland, legal regulations concerning this phenomenon changed on January 1, 2015.

This article attempts to answer the question whether the situation of capital companies has improved or deteriorated in the light of examination of interest as deductible expenses in corporate income tax under the thin capitalization rules. Based on data from the financial statements of the capital accumulated in the database Amadeus, the author conducted an analysis of the parameters specified in the regulations relating to thin capitalization in Poland. The data indicated that the new rules of taxation are more favorable to the total number of companies.