The question of collecting civil law transactions tax (hereinafter: CLTT) on the share capital increase transactions in limited joint-stock partnerships (Polish: SKA) was long open to doubt. In the case of contributions made to SKA for the share capital and simultaneously creating an agio, the problem was to determine the tax base, in other words to answer the question if this was the amount of contribution to the company’s assets or the amount by which the share capital was increased.