Poland: Corporate income tax exemption applied to total revenue from activities performed in special economic zones

Supreme Administrative Court decision

Applied to total revenue from activities performed in special economic zones

The Supreme Administrative Court determined that the corporate tax exemption applied to a company’s total revenue from activities performed in special economic zones.

The case file is: II FSK 1254/20 (15 December 2022)

The company implemented new investment projects eligible for investment support in line with the Polish classification of goods and services (PKWiU) in special economic zones. However, the company was not sure about the scope of exemption provided under Article 17(1)(34a) of the corporate income tax law.

According to the court, the exemption is to be applied to the total revenue earned from the business activities specified in the decision, conducted in the decision-determined area (subject to the appropriate exemption limit). There are no grounds to believe that, in the situation presented by the company, only the income related to the implementation of a given investment project would be exempt.

Read a January 2023 report prepared by the KPMG member firm in Poland


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