Court dismisses claim that foreign contract performance in Poland constitutes Polish tax residency.

The court dismissed the taxpayer's request to be recognized as a Polish tax resident based on the location of contract performance. The taxpayer argued that performing a contract for remuneration in Poland established residency, while the tax authority contended that physical presence and center of vital interests were decisive. The court ruled that mere activity on Polish soil does not automatically create tax residency without meeting the statutory criteria of the Income Tax Act.