As of 1 January 2018, thin capitalisation rules have been replaced by regulations limiting the tax-deductibility of certain debt financing costs. Unfortunately, the new regulations fail to provide clear rules and principles for calculating the amount of debt financing costs excluded from tax-deductible costs and raise significant doubts among experts and taxpayers. Meanwhile, since the beginning of 2018, the director of the National Revenue Information Office has issued a number of tax interpretations concerning the matter in question, in which he presented a position that is disadvantageous for taxpayers.
Poland
