In the case of the Polish CFC rules, in principle, control is not defined directly, but an indication of its meaning can be gleaned from the first (of three) conditions for constituting a CFC. The CFC rules refer to the 50 per cent control threshold and say that a Polish taxpayer controls a foreign company if he owns continuously for at least 30 days, directly or indirectly, at least (i) 50 per cent of the company’s capital (legal control); (ii) 50 per cent of the voting rights in the controlling or administrative organs of the company (legal control); or (iii) 50 per cent of the shares related to the right to participate in the company’s profits (economic control). Moreover, a foreign company whose tax residence is in one of the 26 tax havens is considered a CFC regardless of the level of control over this company, level of taxation of its profits, or type of income received by it (CFC presumption). The Polish CFC rules apply also to the foreign permanent establishment of a Polish taxpayer.