From January 1, 2019 beneficial changes regarding the tax deductible costs with respect to the receivables purchased by a taxpayer from third parties come into force.

So far, the principle was that in case of repayment of a part of such receivables, the cost of their acquisition could only be taken into account in the proportion in which the repayment remained to the value of the purchased receivables. This meant that, for example, in case of purchase of receivables with a nominal value of PLN 1,000 for PLN 200, in case of repayment of the receivable in the amount of PLN 200, the taxpayer (usually a debt collection company) could include in the tax deductible costs only 20% of expenses for its acquisition, i.e., PLN 40, and therefore he achieved taxable income in the amount of PLN 160.

Pursuant to the new regulations, the costs of purchase of receivables may be deducted in full to the amount of income earned from the receivables, up to the moment of settlement of all expenses for their acquisition. As a result, taxable income will not occur in the situation described above. Importantly, the costs of purchasing a package of at least 100 receivables will be settled on the same basis, without the need to separate the acquisition costs of each of them.

⇒ Limitations in taking into account the purchase costs of receivables

The costs of purchasing receivables or their packages will be only reduced by:

• revenues received as a result of settling or disposing of these receivables
• up to the amount of these revenues.

This means that:

• these costs cannot be settled with the revenues from fees, interest, interest for delay in payment of liabilities and penalties accrued after the date of purchase of the receivables or their package,
• a tax loss due to the sale of previously purchased receivables cannot be recognized.