Poland: Deductibility of price adjustments and training expenses under corporate income tax law

Summaries of recent Supreme Administrative Court decisions

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June 18, 2025

The KPMG member firm in Poland prepared a report that includes summaries of the following decisions of the Supreme Administrative Court on June 11, 2025:

  • The court held (case II FSK 1204/22) that expenses incurred by a company as a result of a price adjustment mechanism under concluded contracts may be treated as a tax-deductible cost under Article 15(1) of the CIT Act because the expenses related to the original prices under the contracts and were incurred in order to prevent potential losses and maintain a source of revenue.
  • The court held (case II FSK 1203/22) that expenses incurred by a company to train natural persons running businesses with which the company cooperated, but which were separate and independent businesses, cannot be treated by that company as tax-deductible costs under Article 15(1) of the CIT Act.

Read the June 2025 report

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