Norweskie dochody z pracy marynarzy a ulga abolicyjna. Uwagi na tle orzeczeń NSA o sygnaturach II FSK 370/21 oraz II FSK 451/21
Norwegian Employment Income of Seafarers and the Abolition Relief: Remarks in Light of Supreme Administrative Court Judgments II FSK 370/21 and II FSK 451/21

Summary/Abstract: The article addresses the problem of international tax law and the principles of taxation of individuals who are Polish seafarers earning income from work performed on ships operated in international transport and managed by Norwegian companies. Two judgments of the Supreme Administrative Court were assessed, in which the court did not share the position presented by the tax authorities, denying the possibility of applying the abolition relief in a situation where the income of Norwegian seafarers was subject to tax exemption in Norway. The thesis was verified that it is possible to apply the method of crediting towards tax resulting from the Polish-Norwegian agreement when Norwegian income is not subject to taxation in Norway (in the source country), and consequently it is possible for Polish seafarers to benefit from the abolition relief provided for in the Polish income tax.

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