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Today we discuss an interesting individual tax ruling issued by the Director of National Revenue Information in October 2025, particularly useful to many entrepreneurs and people planning to start a business. The authority agreed with the applicant that expenditure incurred before establishing a business may be recognised as tax-deductible costs.
The facts of the case – what did the Director of KIS’s ruling concern? Training before starting a business, tax-deductible costs and the right to deduct VAT
The case concerned a man who had been taking aircraft pilot training since August 2023. The course was necessary to begin his planned business providing aviation services.
When attending and paying for the course and receiving an invoice in his name without a NIP number, he was an individual who was neither running a business nor registered as a VAT taxpayer.
The training ended in December 2023, and immediately afterwards the applicant registered an aviation services business.
He wondered whether the aircraft pilot training expenditure could be included in tax-deductible costs and whether he could deduct the VAT shown on the invoice received for it.
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Director of KIS: Expenditure incurred before starting a business may be tax-deductible. Its connection with revenue, documentation and absence of exclusions matter
The Director of KIS considered the position presented in the ruling application correct.
The authority cited the Personal Income Tax Act, particularly Article 22, which states that an expense must meet all the following conditions to be recognised as a tax-deductible cost:
- Have a cause-and-effect connection with revenue or its source and be incurred to earn revenue or preserve or secure its source;
- Not appear on the list of costs excluded from tax-deductible costs (specified in Article 23 of the PIT Act);
- Be properly documented.
The Director of KIS found all three conditions met in the situation described. In particular, the authority noted that the applicant’s training was not merely preparation for business activity, but an essential means of starting it. It was therefore connected with the scope of the subsequently established business. The knowledge and skills acquired during training were reflected in the creation or increase of revenue.
The authority also stated that an important fact was that the training expenses were incurred in the same year in which the revenue source arose, meaning the year the business was established.
What does this ruling tell us about accounting for costs incurred before starting a business? Conclusions important beyond aviation!
Contrary to appearances, this decision matters not only to aircraft pilots. The ruling, which also confirms earlier academic and judicial views, clearly shows that expenditure incurred before a business starts may be tax-deductible.
However, proper documentation, an objective connection with the planned activity and no exclusion under Article 23 of the PIT Act are important.
Care is nevertheless needed with any training or courses! In this ruling, the authority explicitly stated that training must be specific and professional in nature. A course aimed at generally improving qualifications is therefore insufficient...
If this article interested you, explore our tax advisory services and read how we can help you:
Summary
Expenditure before starting a business may be tax-deductible
In the ruling numbered 0113-KDIPT2-1.4011.660.2025.6.AS of 9 October 2025, the Director of National Revenue Information agreed with an applicant who argued that aircraft pilot training expenditure could be tax-deductible, after which he registered an aviation services business.
This decision clearly signals that expenditure incurred before starting a business may be tax-deductible, provided that:
- It has a cause-and-effect connection with revenue or its source and is incurred to earn revenue or preserve or secure its source;
- It is not on the list of costs excluded from tax-deductible costs (specified in Article 23 of the PIT Act);
- It is properly documented.
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