Benefits for B2B contractors in Poland and tax-deductible costs – DKIS interpretation

The labour market in Poland is changing dynamically. An increasing number of specialists are deciding to work in the B2B model, establishing sole proprietorships and providing services to Polish companies. Competition for the best experts means that companies – as in the case of full-time employees – offer them a wide range of non-wage benefits.

However, the question arises: can a company classify expenses for such benefits as tax-deductible costs?

This issue was the subject of an individual interpretation issued by the Director of National Tax Information (DKIS). The tax authority confirmed that certain expenses for benefits for self-employed persons may be recognised as tax costs of the company.

When is an expense considered a tax-deductible cost?

The basis for classifying expenses as tax costs is Article 15(1) of the Corporate Income Tax Act (CIT).

In practice, this means that an expense can be a tax-deductible cost if it was actually incurred by the company, is related to its business activity and serves to generate or secure income. In addition, it cannot be included in the list of exclusions, such as representation costs.

What benefits did the company offer?

The interpretation describes a wide range of non-wage benefits offered to B2B contractors in Poland. The company financed, among other things:

• private healthcare packages,
• sports cards allowing access to fitness facilities, swimming pools and group activities,
• specialised courses and trainings to improve the qualifications required for projects,
• language courses supporting cooperation with foreign clients.

At the same time, the company considered expanding its offer with additional benefits, such as insurance, prepaid cards, travel vouchers and access to educational platforms.

Importantly, contractors had freedom in choosing benefits, and the costs were shared – partly covered by the company and partly by the contractor through deductions from their remuneration. Thanks to this, these benefits served as a motivational tool and formed a real part of the cooperation offer.

The company’s argument – connection with income

The company indicated that expenses on benefits are not related to representation or image-building activities. Their purpose is to attract and retain specialists who expect such benefits as part of their cooperation. The lack of a benefits package could directly limit the possibility of implementing projects and thus affect the revenues generated.

In the company’s opinion, benefits are a non-financial supplement, independent of the wage specified in the cooperation agreement. Contractors may voluntarily use them, and the costs are shared – partly financed by the company and partly deducted from the contractor’s remuneration. Each contractor receives information about the value of the benefits and settles them on their own in accordance with applicable tax regulations.

Therefore, the expenses sustained by the company are definitive and directly related to generating and securing income.

Significance of the interpretation for companies

The DKIS position is of significant importance for companies cooperating with self-employed persons in the B2B model. It has been confirmed that expenses for non-wage benefits may be recognised as tax-deductible costs, provided that they meet the general criteria set out in Article 15 of the CIT Act.

As a result, companies gain:

• greater tax certainty when settling expenses for benefits for contractors,
• the ability to build a competitive cooperation offer without the risk that the costs incurred will be questioned,
• a retention tool – benefits become a real factor in retaining specialists, which reduces turnover and promotes project continuity.

The interpretation also underlines that benefits such as medical care, sports cards or language courses are not entertainment costs but rather a necessary element of conducting business and generating income. This is an important signal for companies that want to extend their benefits package to B2B partners as well.

The interpretation of 23 May 2025 is an important confirmation that expenses for benefits for B2B contractors can be classified as tax-deductible costs. The tax authorities have recognised that such benefits, if they meet the general criteria set out in Article 15 of the CIT Act, are directly related to obtaining and securing a source of income, rather than to creating the company’s image.

For companies, this means greater certainty in settlements and the possibility of shaping their benefit policy more freely. However, it is crucial to properly document expenses and demonstrate their connection with business activities.

At getsix®, we support companies in the correct settlement of tax costs, including benefits for B2B contractors. We help ensure compliance with regulations and tax security when implementing such benefits.

If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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