CIT - Outsourced.pl

15 October 2026
R&D employee absences – do holiday and sick leave reduce the tax relief?
15:05 Bydr Piotr Sekulski InCIT
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Do R&D employee absences mean that holiday pay or sick pay must be excluded from qualifying costs? Generally, no. The Polish Minister of Finance has confirmed that employer-funded holiday pay and sick pay may be included in the R&D tax relief calculation. The deduction still depends, however, on the employee’s monthly involvement in R&D activities, appropriate records and the entity that actually finances the relevant payment.

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6 October 2026
R&D tax relief – can a client-commissioned project qualify?
10:41 Bydr Piotr Sekulski InCIT
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Can a Polish company claim R&D tax relief for a project developed specifically for a client? Yes – working under a client contract does not automatically exclude the project from the relief. However, creating a new, customised or technologically advanced product is not sufficient on its own. Recent Polish court judgments show that the decisive factor is the actual development process rather than simply the final result.

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12 August 2026
R&D relief documentation – our article in Prawo.pl
07:24 Bydr Piotr Sekulski InCIT
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Is the fact that a project is innovative or technologically advanced sufficient to claim the Polish R&D tax relief? No. A taxpayer must also demonstrate that the work actually meets the statutory criteria for research and development activity. This is why R&D relief documentation is so important.

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4 August 2026
Agency permanent establishment of a US company in Poland – when does the risk arise?
16:23 Bydr Piotr Sekulski InCIT
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An agency permanent establishment of a US company may arise in Poland where a person acting for the US enterprise has and habitually exercises authority to conclude contracts in its name. The assessment should not, however, be limited to the wording of the relevant agreements. The actual role of the individuals operating in Poland must also be reviewed.

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31 July 2026
IP Box correction – our comment for Rzeczpospolita
18:27 Bydr Piotr Sekulski InCIT
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An IP Box correction may enable a business owner to apply the preferential 5% tax rate to income earned in previous years and recover the resulting tax overpayment. This issue was recently discussed by Rzeczpospolita, with several comments from Dr Piotr Sekulski, tax adviser at Outsourced.pl.

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15 July 2026
MAP application – how to start the mutual agreement procedure in Poland
12:15 Bydr Piotr Sekulski InCIT
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A MAP application formally starts the mutual agreement procedure between the tax authorities of two countries. In the application, the taxpayer must demonstrate that the actions of one or both countries have resulted, or may result, in taxation that is not in accordance with the applicable double taxation treaty.

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11 June 2026
B2B benefits as tax-deductible costs – tax authorities change their approach again
12:16 Bydr Piotr Sekulski InCIT
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B2B benefits as tax-deductible costs have once again become a disputed issue with the Polish tax authorities. In a recent article published by “Rzeczpospolita”, Piotr Sekulski, PhD, tax advisor at Outsourced.pl, comments on the change in the tax authorities’ approach to sports cards, medical packages and other benefits provided to B2B contractors. B2B benefits as […]

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28 May 2026
MAP procedure checklist – what to prepare before submitting an application?
13:56 Bydr Piotr Sekulski InCIT
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A MAP procedure checklist is a practical list of items worth preparing before a taxpayer applies to initiate a mutual agreement procedure. In our previous post, we explained what the MAP procedure is and when it can help in cases of double taxation. This time, we focus on what should actually be checked, collected and organised before submitting the application.

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9 January 2026
MAP procedure: what to do when the same income is taxed in two countries?
21:06 Bydr Piotr Sekulski InBusiness
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Where the same income has been taxed in two countries at the same time, the taxpayer is not without remedies. Many double tax treaties (treaties on the avoidance of double taxation) provide an appropriate tool—namely the MAP procedure (Mutual Agreement Procedure), i.e., the mutual agreement procedure between tax administrations.

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21 November 2025
Form W-8BEN-E checklist – what to check?
11:19 Bydr Piotr Sekulski InBusiness
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When a US counterparty asks your company to sign a form for the IRS and will not wire your fee otherwise, it is very easy to make a mistake. To help our clients, we have prepared this Form W-8BEN-E checklist article. It walks you step by step through what to check and which documents to prepare before you send Form W-8BEN-E. Getting this right helps you avoid paying 30% tax in the US and at the same time stay safe from a Polish tax perspective.

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My name is Piotr Sekulski. I am a Polish tax advisor (entry no. 13740), Doctor of Law from the Jagiellonian University and founder of Outsourced.pl.

I specialize in tax advisory for the IT sector, B2B contractors, founders, technology companies and internationally mobile individuals. I advise clients on lump-sum taxation, PIT, CIT, VAT, Polish tax residency, RSU/ESOP taxation, R&D relief, IP Box, 50% tax-deductible costs and international tax matters.

I gained professional experience in tax advisory firms such as PwC, Thedy & Partners and CRIDO. I have advised on several hundred tax projects for the IT sector, new technologies and creative industries.

In response to numerous inquiries from our clients, we decided to launch a Tax Blog. We discuss current issues regarding the taxation of creative industries and the IT sector. Bearing in mind that that tax law, general law and accounting consist of hundreds of unclear and interrelated regulations, we try to organize the most important information and provide it in an accessible way.

We do not advise on the blog! This blog is supposed to be a source of information - however, each case should be approached individually. For a tax advice, please visit our website.

R&D employee absences – do holiday and sick leave reduce the tax relief?

R&D tax relief – can a client-commissioned project qualify?

R&D relief documentation – our article in Prawo.pl

Agency permanent establishment of a US company in Poland – when does the risk arise?

IP Box correction – our comment for Rzeczpospolita

MAP application – how to start the mutual agreement procedure in Poland

B2B benefits as tax-deductible costs – tax authorities change their approach again

MAP procedure checklist – what to prepare before submitting an application?

MAP procedure: what to do when the same income is taxed in two countries?

Form W-8BEN-E checklist – what to check?

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