The
article presents the current scope of harmonization of tax consolidation
systems within European Union. On the grounds of the Court of Justice of the
European Union (CJEU) judgements author identifies the issues of group taxation
that are already actually harmonized despite the lack of formal directive or
ordinance. The conducted analysis confirm that the Member States (MS) do not have
currently the full discretion in construction of their domestic tax
consolidation regimes. The country lawmaker will have to rethink once again
such elements as the eligible entities, the types of tax integrations or the
scope of tax advantages granted solely to the companies acting as a single tax
entity.