III ARN 47/96
AI generated
Shareholder expenses are deductible only if they constitute employment relationship costs under Polish tax law.
Legislator summary
AI generatedThe 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 generatedArt. 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 generatedart. 16 ust. 1 pkt 38 ustawy z dnia 15 lutego 1992 r. o podatku dochodowym od osób prawnych