Profit repatriation of a Polish subsidiary from tax planning point of view of an international corporation

The main purpose of this study was to examine and compare the possibilities of profit repatriation from the point of view of tax planning of an international corporation, in such a case that a Finnish parent company has a subsidiary in Poland. The main research problem was divided into two sub research problems: 1) to examine concepts and principles of international taxation and tax planning from the point of view of international corporations and 2) to discuss the main features of Polish Companies-, Accounting- and Tax Act from the point of view a Finnish parent company. The research method of this study is mainly decision making, comparative analysis. In this study have been discussed the possibilities of international profit repatriation for supporting the decision making of the management of a Finnish parent company. In addition different repatriation possibilities have been compared. In this study has been noticed that a Finnish parent company can repatriate profit of its Polish subsidiary either directly as dividends or by using indirect methods such as interests, royalties, management fees and transfer pricing of goods. The total tax burden of dividends is heavier than the tax burden of indirect methods. It was also concluded that during the last years the Polish legislation has been renewed in order to prevent hidden dividend distribution. This has been done by implementing new rules of transfer pricing and thin capitalization.

Toiminnanohjausjärjestelmän kehityssuunnat projektipohjaisessa yrityksessä

The master’s thesis focuses on the ERP system of a project company that delivers large-scale industrial plants from a purchasing point of view. The point of time is couple of years after implementation. Opinion of the people working in purchasing is that the ERP system isn’t performing satisfyingly. The first objective for the thesis is to find out the causes of the problems based on theory. It’s possible the system may not be suitable for project business or there may be deficiencies in the system that cause the problems. The second objective for the thesis is to propose solutions to the observed problems based on theory and vision how the system should function. The outcome of the thesis was that the main causes for the problems were connected to the ways of using the system and engineering activities being left outside the scope of ERP. The processes connected to the ERP system are not documented, so the rules for using the system are missing. The thesis describes developing and influences to the organization of a function that enables uploading purchase requisitions to projects from a text file. It was discovered that the function solves many problems and enables other functions that enhance further ambitions to integrate even more of the company’s processes to the ERP system. Conclusion to the thesis is a vision how the system should function and development activities needed to achieve this vision.

Suomen järvien syvyyssuhteet

English abstract

Edustuksellisuus tuloksellisuusarvioinnissa - yt-elimet ja osallisuus kunnallisessa tuloksellisuusarvioinnissa

Abstract: Representativeness in evaluation of efficiency - cooperative organs and participation in municipal evaluation of efficiency