Supreme Administrative Court: The conclusion of a contract with a logistics and warehousing company in Poland does not affect the German company’s core business. Only the place of storage of the goods will be changed. This means that Company B will act as a service provider and not as a subsidiary representative. All decisions regarding the sale of goods will be made by the German company separately. Taking that all into consideration the described situation will not create the permanent establishment in Poland for the Germany company and it will not be obligated to pay incorporate income tax in Poland.
Source Intertax
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