{"id":101277,"date":"2026-10-07T09:00:00","date_gmt":"2026-10-07T07:00:00","guid":{"rendered":"https:\/\/krs-adwokaci.pl\/odsetki-hipotetyczne-art-15cb-cit\/"},"modified":"2026-10-07T09:00:00","modified_gmt":"2026-10-07T07:00:00","slug":"odsetki-hipotetyczne-art-15cb-cit","status":"publish","type":"post","link":"https:\/\/krs-adwokaci.pl\/en\/odsetki-hipotetyczne-art-15cb-cit\/","title":{"rendered":"Notional Interest: An Additional Tax Deduction for Retained Profits and Shareholder Contributions"},"content":{"rendered":"

Updates \u00b7 7 October 2026<\/p>\n<\/div><\/div>

Notional Interest: An Additional Tax Deduction for Retained Profits and Shareholder Contributions<\/h1><\/div><\/div>

Companies subject to CIT, including incorporated companies and partnerships taxed under CIT such as limited partnerships, may claim an additional tax deduction where they finance their business with equity, namely retained profits or additional shareholder contributions. This is known as notional interest under Article 15cb of the CIT Act.<\/p>\n

The mechanism reduces tax without an actual expense being incurred and can also be applied to previous years.<\/p>\n<\/div><\/div><\/div>

<\/div><\/div>
\n
\n
\n
<\/div>\n<\/div>\n\n
<\/div><\/div>\n<\/div>\n<\/div><\/div>

01<\/p>\n<\/div><\/div>

How the Mechanism Works<\/h2><\/div><\/div><\/div>

The deductible amount is the National Bank of Poland reference rate plus one percentage point, multiplied by the retained profit or additional contribution.<\/p>\n

The deduction is available for three years, up to PLN 250,000 per year<\/strong> \u2014 total tax savings may therefore reach approximately PLN 142,500<\/strong>.<\/p>\n<\/div><\/div><\/div><\/div><\/div>

02<\/p>\n<\/div><\/div>

Claims for Previous Years<\/h2><\/div><\/div><\/div>

Companies that have not used the mechanism may claim the deduction retrospectively by amending CIT-8 returns for years that are not time-barred.<\/p>\n

It is worth acting promptly: the 2020 return can only be amended until the end of 2026.<\/strong><\/p>\n<\/div><\/div><\/div><\/div><\/div>

\n
\n
\n

☎︎<\/p>\n<\/div><\/div>\n\n

Would You Like to Speak to Our Experts?<\/h2><\/div><\/div>\n\n

+48 42 207 6666<\/a><\/p>\n<\/div><\/div>\n<\/div>\n<\/div>\n<\/div>

03<\/p>\n<\/div><\/div>

Key Conditions<\/h2><\/div><\/div><\/div>