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Permanent establishment as a foreign direct investment in Poland: identification of tax barriers in the context of new tax development Cover

Permanent establishment as a foreign direct investment in Poland: identification of tax barriers in the context of new tax development

International Journal of Management and Economics
Volume 57 (2021): Issue 2 (June 2021)
By: Marcin Jamroży and  Magdalena Janiszewska  
Open Access
|Jun 2021

Figures & Tables

Figure 1

Foreign branches in Poland over the period 2015–2018.Source: Ministry of Finance.
Foreign branches in Poland over the period 2015–2018.Source: Ministry of Finance.

Figure 2

Geographic structure of FDI inflows in the period 2000–2018 (in billion of USD).Source: own collaboration based on UNCTAD (2000–2019). World Investment Report for years 2000–2018, New York and Geneva.
Geographic structure of FDI inflows in the period 2000–2018 (in billion of USD).Source: own collaboration based on UNCTAD (2000–2019). World Investment Report for years 2000–2018, New York and Geneva.

Figure 3

Income tax levied on branches in 2015–2018 (in thousands of PLN).Source: Ministry of Finance.
Income tax levied on branches in 2015–2018 (in thousands of PLN).Source: Ministry of Finance.

Figure 4

The main PE problem areas addressed in tax rulings.Source: own elaboration. PE, permanent establishment.
The main PE problem areas addressed in tax rulings.Source: own elaboration. PE, permanent establishment.

Figure 5

Frequency of main PE problem areas (in %).Source: own elaboration. PE, permanent establishment.
Frequency of main PE problem areas (in %).Source: own elaboration. PE, permanent establishment.

Figure 6

Problem areas addressed in the judgments of administrative courts.Source: own elaboration.
Problem areas addressed in the judgments of administrative courts.Source: own elaboration.

Figure 7

Frequency with which problem areas are addressed in judgments of administrative courts (in %).Source: own elaboration.
Frequency with which problem areas are addressed in judgments of administrative courts (in %).Source: own elaboration.

Figure 8

Forms of permanent establishments featuring in tax rulings.Source: own elaboration.
Forms of permanent establishments featuring in tax rulings.Source: own elaboration.
DOI: https://doi.org/10.2478/ijme-2021-0011 | Journal eISSN: 2543-5361 | Journal ISSN: 2299-9701
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Language: English
Page range: 177 - 193
Submitted on: Nov 23, 2020
Accepted on: May 21, 2021
Published on: Jun 30, 2021
Published by: Warsaw School of Economics
In partnership with: Paradigm Publishing Services
Publication frequency: 4 issues per year
Keywords:
BEPS,
foreign direct investment,
permanent establishment
Related subjects:
Business and economics,
Political economics,
Economic theory, systems and structures,
Business management,
Management accounting, financial controlling, cost calculation, investment

© 2021 Marcin Jamroży, Magdalena Janiszewska, published by Warsaw School of Economics
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 License.

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