The judgment we managed to secure confirms that a tax group is entitled to fully deduct eligible R&D expenses incurred by each of its members. The deduction limit is based on the taxable amount of the entire group, rather than of the individual group members who incurred the eligible expenses, as was claimed by the tax authorities.
This case significantly strengthens the position of tax groups when it comes to using the R&D relief.
The client was represented by Sendero partner Tomasz Wilk (tax advisor), supported by Katarzyna Olejniczak i Wojciech Chomicz, both consultants in our income tax department. Congratulations for the entire CIT team of Sendero Tax & Legal and great thanks to the client for trusting us!
If you want to know more about this case or about R&D relief opportunities, do not hesitate to contact us!