Wykorzystanie zagranicznego zakładu w międzynarodowym planowaniu podatkowym
The Use of a Foreign Permanent Establishment in International Tax Planning

Summary/Abstract: Purpose – The purpose of this article is to characterize as well as clarify the tax implications of activitieswithe the use of a permanent establishment. Design/methodology/approach – The following research methods were used in the study: studies of literature on the subject, case law and interpretations of tax, analysis of legislation relating to permanent establishment. Findings – The result of this study is to draw attention to the possibility of using permanent establishment in international tax planning. Originality/value – This paper have cognitive value about techniques for apply internetional tax planning based on permanent establishment.

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