Beyond the above described exemption, there is no exemption or exclusion from the Polish CFC rules. However, low actual tax paid by a CFC may be considered as a kind of exclusion from the Polish CFC rules - the tax actually paid by the CFC is lower than the difference between the corporate income tax that would have been charged on the CFC under the Polish tax system and the actual corporate income tax paid by the CFC. For example, if the CFC actually paid more than 9,5 per cent of tax (50% of the Polish 19% ordinary tax rate for corporate taxpayers), while the corresponding Polish company would have been paid 19%, then the CFC's is excluded from the taxation under the Polish CFC rules (in fact such company would not be considered as a CFC because it will not meet on of the three conditions to become a CFC, i.e. low level of actual taxation).