Legislator Case Law & Legislation
III ARN 47/96 AI generated

Shareholder expenses are deductible only if they constitute employment relationship costs under Polish tax law.

Case Number III ARN 47/96
Court / Authority
Jurisdiction Poland (PL)
Decision Date
Outcome Dismissed

Legislator summary

AI generated

The Supreme Court dismissed the extraordinary review against the tax office's decision regarding a company's 1993 tax liability. The tax authority argued that expenses paid to shareholder-managers were not deductible because they did not stem from an employment relationship. The court upheld this view, rejecting the taxpayer's claim that the expenses should be treated as business costs.

Legislator headnote

AI generated

Art. 16 ust. 1 pkt 38 ustawy o podatku dochodowym od osób prawnych: Expenses paid to shareholders are deductible only if they result from an employment relationship with the company.

Keywords

AI generated
Polish tax law shareholder expenses deductibility of costs employment relationship extraordinary review tax office decision company management

Cited Legislation

AI generated
art. 16 ust. 1 pkt 38 ustawy z dnia 15 lutego 1992 r. o podatku dochodowym od osób prawnych

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