Wybrane problemy podatkowe w praktyce funkcjonowania przedsiębiorstw górniczych
Selected tax issues in the operational practice of mining enterprises

Summary/Abstract: The article examines selected tax issues related to the operations of mining companies in Poland,in particular the tax aspects of mining damage, as well as doubts concerning expenditure onthe implementation of corporate social responsibility (CSR), public law subsidies and propertytax. The study aims to identify the solutions to these problems endorsed by jurisprudence andinterpretative practice, while assessing the internal consistency of the positions taken by the taxadministration and administrative courts. The author employs the dogmatic-legal method, basedon an analysis of legal provisions, court rulings, and individual tax interpretations from 2020–2025.The findings indicate that tax authorities often adopt a restrictive stance, e.g., regarding theclassification of CSR expenditures as tax-deductible costs, whereas courts tend to favor a moreflexible approach. In the case of mining damages, the study confirms the possibility of recognizingrepair costs as tax-deductible expenses, while in the context of subsidies, it demonstrates differencesin expenditure classification depending on the form of support. The author argues that, giventhe growing importance of CSR in business operations, official tax guidelines should be issuedregarding the tax treatment of expenditures related to its implementation. The role of internal consistencyof tax authorities’ positions regarding the assessment of identical issues is also emphasised.

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