Subsidy from PFR under the Financial Shield and CIT and PIT

The Ministry of Finance in a communication of 18 May 2020 stated that from the point of view of income taxes, such a subsidy is a loan. As a result, its receipt is not revenue and its return is not deductible. On the other hand, the costs financed from the funds granted under the Financial Shield are qualified as tax deductible expenses on general terms.All expenditure which has been covered by the funds provided by the PFR is eligible for inclusion in tax costs if it meets the general conditions laid down by tax laws for such eligibility. The classification of expenses as tax deductible costs also does not change the possible cancellation of financing. On the other hand, the cancelled part of the subsidy in the current state of law constitutes tax revenue, although the Ministry of Finance has reserved that it is examining the issue of exemption from taxation of such cancellation. In addition, the amount of the subsidy received is not subject to civil law transaction tax.