(I) The Polish CFC rules do not apply to a non-resident company if the non-resident company is established and subject to tax on the worldwide income in a EU/EEA country, provided it meets the substantial real economic activity test. 
(II) In order to avoid double taxation (in the economic sense), a tax deduction has been introduced for the amount of income tax paid by a foreign controlled company in its country of residence. This deduction is made in the proportion in which the income of this company determined for the purposes of the CFC regulations (i.e., the income included in the tax base, after deducting the amounts of dividends received by the taxpayer from the foreign controlled entity and the amounts obtained from the taxpayer's disposal of its interest in the foreign controlled company for consideration) remains to the total income of this company. 
(III) Elimination of double or multiple income taxation on CFC income in cases of cascading dividends in holding structures