Poland’s tax authority clarifies that disabled rehabilitation fund payments don’t qualify for Estonian CIT.
KAS Position on PFRON Payments
According to the Head of KAS, payments to PFRON are not considered expenses unrelated to the company’s business activities. The tax authority has maintained this position for some time.
Supporting Evidence from 2025
Individual interpretations from December 23, 2025 (ref. 0111-KDIB1-1.4010.536.2025.2.KM), December 3, 2025 (ref. 0111-KDWB.4010.147.2025.2.KP), and July 15, 2025 (ref. 0111-KDIB1-1.4010.311.2025.1.RH) confirmed that such payments are neither unrelated business expenses nor hidden profits.
Implications for Companies
Companies that incur these payments to PFRON are therefore not required to pay Estonian CIT for this specific expense.
The Revoked Interpretation
However, the individual interpretation from November 30, 2022 had to be revoked due to procedural issues. The Head of the National Tax Information Office independently assessed the nature of other PFRON payments made upon termination of contracts with disabled employees, even though the company had not specifically asked about these.
