Planowanie podatkowe działalności prowadzonej poprzez zagraniczny zakład

The purpose of this article is to characterize as well as clarify the tax implications of foreign direct investment in the form of a permanent establishment. The tax burden is not a fixed amount determined by the business environment but rather can be influenced by the type of business structure created. A tax analysis of foreign direct investment (FDI) has revealed that the creation of a permanent establishment is more fiscally profitable than the creation of a separate legal entity (subsidiary). The income of a permanent establishment is not subject to economic double taxation. In addition, there is more flexibility with a permanent establishment in other areas of decision-making such as financing, internal dealings or the settlement of losses.