Invoice Issued Outside KSeF Still Deductible for Corporate Income Tax

Article In one of its latest individual rulings, Poland’s Director of the National Revenue Information (Dyrektor KIS) clarified whether an invoice issued in breach of the mandatory National e‑Invoicing System (KSeF) rules can still form the basis for recognising an expense as tax‑deductible. As reported by Infor.pl, the answer for corporate income tax (CIT) is yes. [ksiegowosc.infor.pl]

The applicant—an active VAT and CIT payer within an international group, obliged from 1 February 2026 to receive structured invoices via KSeF—noted that some suppliers still issue paper or electronic invoices outside the system, over which the buyer has no control. The KIS ruled the taxpayer’s position correct in full for CIT purposes: an issuer’s KSeF error does not deprive the purchaser of the right to deduct the cost. [ksiegowosc.infor.pl]

The reasoning rests on the fact that eligibility to treat an expense as a tax cost is governed by Article 15(1) of the CIT Act, not by the technical medium on which the transaction information is recorded. The KIS stressed that, unlike the VAT Act, the CIT Act contains no changes making cost status dependent on invoice form, and that later resubmission of the same invoice via KSeF does not alter the CIT outcome—confirming a consistent interpretive line (see also the TCE Kancelaria commentary on ruling 0111‑KDIB2‑1.4010.85.2026.4.AG). [ksiegowosc.infor.pl], [tcekancelaria.pl]