When assessing whether a CFC carries out real economic activity, the Polish CFC rules recommend paying particular notice to whether: 
(i) the registration of a CFC matches an actual establishment intended to carry on real economic activities, i.e. the company has local, qualified personnel and the requisite equipment; 
(ii) a CFC has not been created as a structure functioning in isolation from economic reasons; 
(iii) the premises, personnel or equipment of a CFC are commensurate with the scope of its activities; 
(iv) arrangements concluded by a CFC are consistent with economic reality, have an economic justification, and are not manifestly contrary to the general economic interests of the company; and 
(v) a CFC independently performs its basic economic functions with the use of its own resources, including managers at the company’s location.