III RN 22/01
AI generated
Court allows deduction of purchase costs only in tax years where corresponding sales revenue is realized.
Legislator summary
AI generatedThe Supreme Court allowed the taxpayer's appeal against the tax authority's refusal to recognize purchase costs as deductible expenses. The taxpayer argued that the timing of the expense, not the revenue, should determine deductibility, while the tax authority insisted costs must be offset against income in the same year. The court ruled that under the Income Tax Act, costs are deductible only in the tax year where the corresponding revenue is earned, establishing a strict link between expense and income realization.
Legislator headnote
AI generatedArt. 15 ust. 1 i 4 ustawy o podatku dochodowym od osób prawnych: costs incurred for business purposes are deductible only in the tax year in which the corresponding revenue is realized.
Keywords
AI generated
income tax deduction
costs of acquisition
matching principle
tax year alignment
revenue realization
corresponding income
deductibility timing
Cited Legislation
AI generatedArt. 15 ust. 1 and 4 of the Income Tax Act for Legal Persons
Art. 22 ust. 2 pkt 1 of the Act on the Supreme Administrative Court