In times of globalization, the activity of international holding companies has become crucial for the economy of the European Union. Increasingly, holding companies employ aggressive tax optimisation in their strategies. While the tax policies of individual EU Member States have turned out to be of little effectiveness. Simultaneously, the lack of a common and harmonized tax policy for countering tax optimisation has become a serious problem for the European Union. Therefore, the European Commission strives to develop a fiscal concept which will – on the other hand – allow to effectively combat international tax optimisation adopted by holding companies and – on the other hand – be integral with the internal tax systems of individual Member States. The paper constitutes an attempt at conducting a comparative analysis of various conceptions of taxation of international holding companies. Special attention is devoted to the CCCTB conception (which is a legislative proposal put forward by the European Commission as well as the ECUIT, CHSTB, and HST which may be seen as important sources of experiences and supporting solutions.
