From January 1 2018, research and development (R&D)
expenses may be deducted twice for tax purposes in Poland.
Besides many changes that, from January 1 2018, will
significantly increase the income tax cost of Polish companies,
there is one which may help to reduce the burden. It is the
R&D tax allowance.
From January 1 2018, companies will be allowed, in addition
to the regular deduction of such cost, to deduct them once
again from a taxable basis, so there is an increase of the
limit of deduction to 100% of eligible costs. There is no other
limit for the R&D allowance.
It has been clarified that, in the case of R&D costs of
employees, the eligible costs are salaries and social security
contributions paid with respect to the employment relationship,
in a part that time which an employee spends on R&D
activity relates to the total working time of the month.
The catalogue of eligible R&D human work costs was
extended to cover not only pure labour employment but also fees
under specified task contracts and mandate contract, including
related social security contributions, in a part that time
which a contractor spends on R&D activity relates to the
total working time of the month.
Also, the catalogue of eligible tangible R&D expenses
was extended to cover the purchase of specialist equipment, in
particular vessels and laboratory equipment and measuring
devices that are not fixed assets.
However, with respect to eligible cost being expert
opinions, it was clarified that only expert opinions,
consultancy services and equivalent services, provided or
performed on the basis of a contract with a scientific unit, as
well as the acquisition of research results from such an
entity, for the purposes of conducted R&D activities will
qualify for the allowance.
The most expected change allowing the use of R&D tax
relief for taxpayers conducting business on the basis of a
permit in the special economic zone (SEZ) with respect to
eligible costs that are not included in the calculation of the
tax exempt income based on the SEZ permit was eventually
The R&D allowance can therefore be a useful and easy
remedy to the increase of income taxation just introduced to
Polish tax system.
Monika Marta Dziedzic (firstname.lastname@example.org)
Tel: +48 (22) 322 68 88