Limit on tax-deductible expenses on intangible services
The list of rights and services subject to the limit is open, as it also covers “services of a similar nature”. This gives rise to businesses having trouble correctly recognising those rights and services as tax-deductible expenses. Applying the regulations on the limited tax-deductible expenses on intangible services purchased from affiliated entities still gives rise to many concerns. Even though the provisions specified in Article 15e of the CIT Act became effective on 1 January 2018, their implementation in practice still causes much trouble.

For more on this topic, see the article by Andrzej Jagiełło, our tax advisor, in Rzeczpospolita on-line, Dobra Firma weekly or here.