Taxing Incomes Derived from Economic Activity of Residents and Non-Residents Within The Territory of The Republic of Poland

Abstract

The main aim of this doctorial work was to give an overall view of the issue of taxation of income derived from sources on Polish territory by non-residents and by residents outside Polish territory. Besides the stated goal, a further point was to show the main faults in Polish legislature with respect to foreign investors. At the start of the work, there is a summary of the aims and goals of the work and it briefly touches on an overview of the individual chapters. The second chapter of the work covers the genesis of the tax issue in international relations, where, amongst others, is put forward the OECD sample agreement according to which the Republic of Poland signs contracts for the prevention of double taxation with the majority of countries. The following chapter is dedicated to forms foreign subjects do business in the Republic of Poland and briefly, touches an overview of the forms of business these people do. Determining the tax domicile is very important for taxing the income of non-residents. The fourth chapter deals with the tax domicile of physical and corporate entities. The key chapter of the work is the fifth chapter, where taxation of the income of both residents and non-residents is dealt with. In this chapter, the issue of taxing income derived from sources on Polish territory of non-residents, either from direct or from indirect trade, both for physical and corporate entities and of incomes of residents derived from sources outside Polish territory; an analysis of this taxation as well as the use of various methods of taxation is carried out. In conclusion, a synopsis of the work is given, covering the issue of taxation of income in relation to foreign countries and showing the main flaws in this area within the framework of the Republic of Poland.