Poland: Application of Estonian CIT regime; taxation of gain from real estate as income from non-agricultural business activity
Summaries of recent Supreme Administrative Court decisions
The Supreme Administrative Court recently held that:
- Expenses financed from profits generated in years preceding election of the Estonian CIT regime are not subject to Estonian CIT (case file II FSK 733/23).
- Gain from a sale of real estate never used in any business activity was not taxable as income from non-agricultural business activity under Article 10(1)(3) of the PIT Act (case file II FSK 734/23).
Read a March 2026 report prepared by the KPMG member firm in Poland