Abstract
This paper deals with a scope of jurisdiction to tax and its influence on CFC rules and their application. Defining this relationship is a prerequisite for examining both tax structures using CFCs and CFC rules as a tax law measure aimed at minimalizing the tax consequences of these structures, which are unwanted from the point of view of the state applying CFC rules.
The paper summarizes the legal titles and their aspects from which states derive tax jurisdiction and its scope. These titles are primarily a tax residence and a source of income.
It also deals with terms taxpayer and income, the definitions of which are a prerequisite for determining the jurisdictional titles and jurisdiction to tax itself.