Ograniczenie zakresu stosowania w Polsce autoryzowanego podejścia OECD dotyczącego przypisywania zysku do zagranicznego zakładu
Limitation in scope of applying the authorized OECD approach in respect to profit allocation to the permanent establishment in Poland

Summary/Abstract: The scope of the article covers the application of the authorized OECD approach to permanent establishment with respect to double tax treaties to which Poland is a party as well as domestic provisions. The focus is on assumption introduced to domestic law since 2019 that relations between permanent establishment and its headquarter are equal to the relations between associated companies. In consequence, application of domestic provisions on permanent establishment creates situation of double taxation or double non-taxation of income.

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