Background & facts of the case The case related to the Polish flagship programme of regional investment aid customarily referred to as Special Economic Zones (SEZ), which essentially provides an exemption from corporate income tax (CIT) in an amount proportionate to investment costs incurred by an investor in an eligible location. The exemption is awarded on the basis of a SEZ permit issued by SEZ authorities, and is being utilized by the investor through gradual set-off of the aid (of the exemption amount) from the annual CIT liability, up to a point when the aggregate amount of such set-offs equals the maximum amount of the state aid stemming from the SEZ permit. In addition to the above, older SEZ permits included also a clause indicating explicitly the date of expiry of the
The Polish Supreme Administrative Court issues a decision on the applicability of regional investment aid for a tax exemption and the maximum amount of aid that may be granted in an administrative decision
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