Poland: Interest Capitalisation To Trigger Taxable Revenue

Capitalised loan interest in Poland becomes taxable revenue on the date of its capitalisation and not on the date when it is received – so stated the Supreme Administrative Court in its ruling of 13 December 2013, file no. II FSK 2849/11.

Although that ruling follows the suit of the long standing case law, the lower instance tax authorities still often stray from this path during tax inspections. That is why, if you deal with interest capitalisation in Poland, you may want to consider obtaining an advance tax ruling. We would be glad to elaborate on this subject and assist you in drafting an application for such a ruling.