The research and development relief may include also salaries of personnel from non-R&D departments or personnel whose scope of responsibilities does not expressly comprise R&D work, on condition such personnel’s actual activities are related to R&D. As explained by the Director of National Revenue Information in his tax ruling of 17 October 2017 (ref. 0111-KDIB1- 3.4010. 207.2017.3.MST), tax regulations permit the deduction of amounts payable to personnel engaged in working for research and development purposes. This has led the tax authority to a conclusion that whether and to what extent any salary may be deducted under this relief depends on the actual pursuit of R&D activities.
For the full text of the article in Polish, see Rzeczpospolita on-line and here.