Can foreign entities be included in a Tax Group?
Foreign company, that is not a Resident Person, cannot qualify to be a member of a Tax Group. However, if a foreign company directly or indirectly holds shares or interests of several juridical Resident Persons including a Parent Company, in such case juridical Resident Persons (Subsidiaries of the foreign company) can form a Tax Group provided that such companies are held by a Parent Company which is a juridical Resident Person and meets all of the conditions under Article 40(1) of the Corporate Tax Law such that it qualifies as the Parent Company of the Tax Group.