Thin capitalization in Polish tax law

Thin capitalization in Polish tax law


Mikołaj Kondej


Author in his article describes thin capitalization issues in Polish tax law. Publication covers situations in which interest from loans granted by shareholder may not be treated as tax deductible item. Rulings of Directors of Tax Chambers as well as Court Rulings are quoted so as to clarify the disputed issues. At the end of the article author presents ways of avoiding limitations imposed by thin capitalization.


thin capitalization, interest, intercompany, loans, tax, tax law, CIT, corporate income tax

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