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Risk Advisory – ALTO with new Partner and new service line

Risk Advisory – ALTO with new Partner and new service line

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Wages for absence and R&D relief

Case study

Tax

In the light of the recent positive judgments of the administrative courts, will the treasury finally change its unfavourable position on wages for absence for taxpayers?

 

Since the introduction of the R&D relief, the most controversial issue has been which expenditures can be included as eligible costs, as confirmed by the numerous individual interpretations regularly issued by the Director of National Tax Information (Director of NTI).

Most queries and doubts of taxpayers relate to personnel costs. They constitute one of the most frequently incurred eligible costs under the R & D relief.

The NTI Director has for a long time consistently taken the position that employee remuneration costs incurred by a taxpayer for the period of justified absence of an employee from work (e.g. sick pay, holiday pay) cannot constitute eligible costs. This position is presented despite a fairly uniform line of rulings by administrative courts in this respect. Recently, there have been a number of judgments by administrative courts, including the Supreme Administrative Court, which challenge the correctness of the NTI Director’s interpretation.

Will the NTI Director finally change his position? It is difficult to predict this. However, recent rulings by administrative courts indicate that in the near future, disputes will concern not whether a given personnel cost (including the cost of remuneration for an employee’s absence) can constitute an eligible cost, but how to calculate the proportion in which personnel costs (including the cost of remuneration for an employee’s absence), should be included in eligible costs.

 

When accounting for R&D relief, have you also wondered how to correctly account for employee costs as eligible costs? Should you have a difficulty with this, please do not hesitate to contact us! At ALTO we will present you with possible approaches in this respect.

Involved in the project:

Żaneta Chojnacka

R&D Expert & Business Development Specialist

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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

Marcin Domagała, PhD

Managing Partner / Risk Advisory

Marcin is a Managing Partner of the ALTO Risk Adisory business line and an experienced leader whose career has led from the world of science to business.

Ewa Solarz

Managing Partner / ESG

Ewa is the Managing Partner leading the ESG team at ALTO. She specialises in sustainability and ESG consulting.

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.

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