New Tax Reality for Permanent Establishment of Foreign Enterprises in Poland in a Post-Beps Era

IF 1.3 Q1 LAW
Maciej Jamroży, Magdalena Janiszewska, F. Majdowski
{"title":"New Tax Reality for Permanent Establishment of Foreign Enterprises in Poland in a Post-Beps Era","authors":"Maciej Jamroży, Magdalena Janiszewska, F. Majdowski","doi":"10.4467/22996834flr.22.020.16529","DOIUrl":null,"url":null,"abstract":"The main aim of this contribution is to make a review and assess the application of BEPS Action 7 recommendations by the tax administration in Poland when determining whether a non-resident enterprise operating in Poland should be considered to have a permanent establishment (PE). The creation of a PE is crucial for taxable presence in Poland and for identifying the scope of the allocated revenues and expenses (taxable income). Changes to the OECD Model have a genuine practical impact on multinational enterprises and tax administrations and thus they need to be closely examined. The considerations serve to prove the hypothesis that Polish tax authorities apply the","PeriodicalId":54052,"journal":{"name":"European Company and Financial Law Review","volume":"56 1","pages":""},"PeriodicalIF":1.3000,"publicationDate":"2022-09-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":null,"platform":"Semanticscholar","paperid":null,"PeriodicalName":"European Company and Financial Law Review","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.4467/22996834flr.22.020.16529","RegionNum":0,"RegionCategory":null,"ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"Q1","JCRName":"LAW","Score":null,"Total":0}
引用次数: 0

Abstract

The main aim of this contribution is to make a review and assess the application of BEPS Action 7 recommendations by the tax administration in Poland when determining whether a non-resident enterprise operating in Poland should be considered to have a permanent establishment (PE). The creation of a PE is crucial for taxable presence in Poland and for identifying the scope of the allocated revenues and expenses (taxable income). Changes to the OECD Model have a genuine practical impact on multinational enterprises and tax administrations and thus they need to be closely examined. The considerations serve to prove the hypothesis that Polish tax authorities apply the
后beps时代外国企业在波兰永久设立的新税收现实
本贡献的主要目的是在确定在波兰经营的非居民企业是否应被视为拥有常设机构(PE)时,审查和评估波兰税务管理部门对BEPS行动7建议的应用情况。PE的创建对于在波兰的应税存在以及确定分配的收入和费用(应税收入)的范围至关重要。经合组织模式的变化对跨国企业和税务管理产生了真正的实际影响,因此需要对其进行密切审查。这些考虑有助于证明波兰税务机关适用的假设
本文章由计算机程序翻译,如有差异,请以英文原文为准。
求助全文
约1分钟内获得全文 求助全文
来源期刊
CiteScore
1.00
自引率
16.70%
发文量
13
期刊介绍: In legislation and in case law, European law has become a steadily more dominant factor in determining national European company laws. The “European Company”, the forthcoming “European Private Company” as well as the Regulation on the Application of International Financial Reporting Standards (“IFRS Regulation”) have accelerated this development even more. The discussion, however, is still mired in individual nations. This is true for the academic field and – even still – for many practitioners. The journal intends to overcome this handicap by sparking a debate across Europe on drafting and application of European company law. It integrates the European company law component previously published as part of the Zeitschrift für Unternehmens- und Gesellschaftsrecht (ZGR), on of the leading German law reviews specialized in the field of company and capital market law. It aims at universities, law makers on both the European and national levels, courts, lawyers, banks and other financial service institutions, in house counsels, accountants and notaries who draft or work with European company law. The journal focuses on all areas of European company law and the financing of companies and business entities. This includes the law of capital markets as well as the law of accounting and auditing and company law related issues of insolvency law. Finally it serves as a platform for the discussion of theoretical questions such as the economic analysis of company law. It consists of articles and case notes on both decisions of the European courts as well as of national courts insofar as they have implications on European company law.
×
引用
GB/T 7714-2015
复制
MLA
复制
APA
复制
导出至
BibTeX EndNote RefMan NoteFirst NoteExpress
×
提示
您的信息不完整,为了账户安全,请先补充。
现在去补充
×
提示
您因"违规操作"
具体请查看互助需知
我知道了
×
提示
确定
请完成安全验证×
copy
已复制链接
快去分享给好友吧!
我知道了
右上角分享
点击右上角分享
0
联系我们:info@booksci.cn Book学术提供免费学术资源搜索服务,方便国内外学者检索中英文文献。致力于提供最便捷和优质的服务体验。 Copyright © 2023 布克学术 All rights reserved.
京ICP备2023020795号-1
ghs 京公网安备 11010802042870号
Book学术文献互助
Book学术文献互助群
群 号:481959085
Book学术官方微信