For the existence of a permanent place of business, it is not enough to have a structure characterized by sufficient stability in Poland. It is important that this structure, in terms of personnel and technical resources, allows the receipt and use of purchased services for the own needs of this permanent place. Additionally, the same personnel and technical resources cannot be used simultaneously to provide and receive the same services.
This was the ruling of the Supreme Administrative Court in its judgment of May 19, 2022 (I FSK 968/20).
Source
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