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Statistical classification PKWiU as an element of fact or an element of legal norm - practical problems in scope of applying for individual interpretation (tax ruling)



Subject and Keywords:

limit for intangible services   PKWiU   tax ruling


Providing the statistical classification (so called: PKWiU) in applications for individual interpretation of tax law regulations raises more and more practical doubts. Especially regarding the calling on taxpayers to provide such a classification in case of questions about the limit for recognizing as tax deductible costs expenses on intangible services. The catalogue of services covered by this limit is an open catalogue, which causes not only doubts of taxpayers regardingthe classification of purchased services in this respect, but also a certain uncertainty of tax authorities and a desire to facilitate their position by relying on the classification. The purpose of this article is to present whether the tax authorities can in any case expect this classification to be given (as an element of the facts) or whether they are obliged to determine it on their own (by decoding the legal norm resulting from the provision).


Uniwersytet Wrocławski. Wydział Prawa, Administracji i Ekonomii

Date issued:







Kwartalnik Prawno-Finansowy, ISSN 2544-8382 ; nr 4/2019, s. 29-42

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Kwartalnik Prawno-Finansowy

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Copyright by Uniwersytet Wrocławski

Autor opisu:

WR U/PAdal