Poland tax updates: NSA ruling on bond disposal and Estonian CIT guidance

The Supreme Administrative Court (NSA) has ruled on the accounting of revenue from the disposal of bonds for Corporate Income Tax (CIT) purposes. The court determined that for tax purposes, taxpayers must separately recognize revenue and the corresponding tax costs rather than simply reporting the net accounting result. This distinction is critical when allocating indirect costs between different revenue pools, such as capital and operating income, as the tax revenue must be identified independently of the balance sheet result.

Separately, discussions regarding the Estonian CIT model in Poland continue for 2026. This mechanism allows companies to defer taxation by keeping profits within the business for reinvestment, rather than paying tax on realized income. However, the model requires compliance with specific conditions regarding legal form and ownership structure. Tax liability is triggered primarily upon the distribution of profits or through specific categories of benefits and expenditures, rather than the mere achievement of profit.