Important now

ALTO joins an international association Allinial Global

ALTO joins an international association Allinial Global

ALTO at Gdański Business Center from October 2nd

ALTO at Gdański Business Center from October 2nd

“Friendly Workplace” distinction for ALTO

“Friendly Workplace” distinction for ALTO

Numerous awards in ITR World Tax and ITR World TP 2024

Numerous awards in ITR World Tax and ITR World TP 2024

R&D relief as a remedy for the so-called ‘minimum tax’?

Case study

Tax

Based on the provisions of the Polish Order, from 2024, companies that conduct extensive investment activity in Poland and generate a loss or achieve a profitability of less than 2% will be obliged to pay a new tax – the so-called minimum tax. If such entities conduct R&D activities, will they have the possibility to reduce the tax base for this tax by the R&D relief to which they are entitled?

Recently, there have been positive interpretations of the Director of National Fiscal Information (e.g. 0111-KDIB1-3.4010.101.2022.1.MBD; 0111-KDIB1-3.4010.580.2022.2.JKU), from which it follows that if the Company meets the criteria for inclusion in the so-called minimum tax and the requirements for taking advantage of the R&D relief, the provisions of the Corporate Income Tax Act allow for the possibility of reducing the tax base for the minimum tax by the R&D relief. The authority also ruled positively on the possibility to deduct the unused amount of relief accumulated from previous tax years. This is good news, as in light of the wording of the minimum tax provisions, as well as the transitional provisions, this is not obvious.

 

Why is it important?

The minimum tax will affect almost all businesses – including, for the first time, those incurring a tax loss. To date, many companies, despite being engaged in R&D activities, do not account for the R&D relief – also due to their inability to deduct it in a given year as a result of a recorded loss or realistically small savings related to the low margin nature of their business. From next year, the R&D relief may be a significant opportunity for them to reduce their tax burden.

If you are running a growth-oriented business and already know that the minimum tax will apply to your business, don’t hesitate! Get in touch with us – we can help you effectively and safely implement R&D relief in your organisation.

 

At the same time, it should be clarified that there are currently two concepts under the notion of minimum tax – i.e. a national and a global minimum tax, introduced on the basis of the adopted EU Directive. Contrary to the Polish version, the global one does not offer the possibility of combining it with R&D relief – the exceptions of not imposing a compensatory tax include refundable reliefs, the specificity of which is not covered by Polish tax incentives.

Involved in the project:

Żaneta Chojnacka

R&D Expert & Business Development Specialist

You may be interested:

Case studies:

Tax

Wages for absence and R&D relief

Wages for absence and R&D relief

Tax

200% write-off under R&D relief vs. an individual interpretation

200% write-off under R&D relief vs. an individual interpretation
See all

Knowledge base:

Tax

16 February 2024

[ALERT ALTO]: Latest updates of the National e-Invoicing System (KSeF) are available on the Ministry of Finance website, along with FAQs.

We would like to inform you that the website of the Ministry of Finance has published a section of questions and answers concernin...

Read more
[ALERT ALTO]: Latest updates of the National e-Invoicing System (KSeF) are available on the Ministry of Finance website, along with FAQs.

Tax

26 January 2024

Mobile workers - important and favorable reasonings of courts and tax authorities

Accommodation costs during business assignments On January 9th this year, the Supreme Administrative Court (NSA) once again affir...

Read more
Mobile workers - important and favorable reasonings of courts and tax authorities
See all

Why ALTO?

At ALTO people are the key. It is them who, thanks to their knowledge and experience, are able to provide comprehensive support in implemented projects, taking care of the highest quality of services, therefore ensuring a sense of comfort and safety to our clients.

Learn more!

We act globally

We are a member of Allinial Global - an association of independent advisory and accounting firms leveraging the global and local knowledge and experience of 38,000 outstanding professionals from more than 260 renowned firms in 107 countries.

13+ years of experience

Our long-standing presence on the market allows us to look at the business from a cross-sectional perspective - we know what to do and how to do it to support you in achieving your goals.

150 people in the team

A constantly growing group of experts can contribute to the success of your company.

10,000+ cases

We help in both everyday aspects of running a business and in emergencies.

Paweł Fałkowski

Chief Executive Officer

Paweł is the firm’s CEO and co-founder at ALTO.

Kamil Lewandowski

Chief Growth Officer

Kamil is a co-founder and CGO at ALTO. He is responsible for the development strategy of the ALTO group. Additionally, he oversees activities in the area of ​​business development and marketing.

Sylwia Kulczycka

Partner & Tax Advisor

Sylwia Kulczycka is a Managing Partner of the TAX business line at ALTO. She specializes in tax advisory services for the life sciences, IT and professional services industries.

Aleksandra Bońkowska

Partner & Tax Advisor

Aleksandra is a partner at ALTO. Before joining ALTO team, she worked in one of the big four companies. For many years, Ola has been advising clients in the financial industry, including in particular insurance companies, payment market institutions ...

Daniel Banach

Partner & Tax Advisor

Daniel is a partner at ALTO. He specializes in tax advisory for financial investors (mainly private equity funds) and for clients from the real estate industry.

Tobiasz Dolny

Partner & Tax Advisor

Tobiasz is a Partner at ALTO. He is the leader of a dedicated team at ALTO focused on tax advisory for investment funds and asset managers. His main areas of expertise include CIT, VAT and tax settlements of financial institutions

Rafał Tołwiński

Partner & Tax Advisor

Rafał is a licensed tax advisor with over 15 years of experience. He is also the Head of Personal Tax Services team, operating within the group’s Tax service line.

Meet Us

Any questions?
Write to us or call us.

+48 22 652 27 51


    Administrators of the personal data are companies from the ALTO Group. More information on the processing of personal data is available in the privacy policy.

    Always be up to date,
    Receive ALTO Alert

    *By submitting the application, you consent to the processing of personal data in accordance with Privacy policy
    and confirm acknowledgement of the information clause