Jeszcze o koszcie jako wydatku związanym z przychodami. Racjonalność działania podatnika jako przesłanka rozpoznania kosztu podatkowego
More about a cost being an expense related to revenues. Rationality of taxpayer actions as prerequisite for disclosing tax deductible cost
Author(s): Mikołaj KondejSubject(s): Law, Constitution, Jurisprudence
Published by: Wydawnictwo Uniwersytetu Łódzkiego
Keywords: rationality of the taxpayer actions;rationality of incurring the cost;adequacy of the tax deductible cost;tax deductible cost;prerequisites for disclosing tax deductible cost
Summary/Abstract: The article discusses whether economical rationality of an expense is required to disclose it as a tax deductible cost on grounds of Polish income taxes. In particular the author considers whether to deduct the expense for tax purposes there is a requirement that the taxpayer holds legitimate expectation that such expense results in income higher than the amount of expense itself. He argues that introduction of such requirement would remain contrary to the idea of income tax, being the tax on top of increase of taxpayer assets. Consequently, he claims that the legal definition of tax deductible cost does not provide the tax authorities with grounds to challenge tax deductibility of costs based on their rationality.
Journal: Kwartalnik Prawa Podatkowego
- Issue Year: 2018
- Issue No: 4
- Page Range: 93-109
- Page Count: 17
- Language: Polish