Publication date: December 02, 2025

Planning, analysis, and software design; work on program development and its implementation; integration of the software with other systems and support for the implementation of system updates – taxation issues

Facts in the case

The complainant ran a business whose primary purpose was to produce computer programs and implement programming projects. As part of this business, based on his knowledge of information technology and experience in developing solutions related to computer program development, he accepted programming assignments for his clients. He requested an individual tax ruling from the Director of the National Tax Information Service regarding personal income tax. For the purposes of describing the factual circumstances, the complainant divided his business into individual stages, including: planning, analysis, and software design; work on program development and its implementation; integration of the software with other systems and support for the implementation of system updates. As a result of this work, computer programs were created, understood as works under Article 1 of the Polish Copyright and Related Rights Act. Considering the broad definition of a computer program, the complainant stated that each of the indicated results of the work constituted a work and was protected (Article 74 of the Copyright and Related Rights Act). According to the complainant, the software he produced was based on individual, original ideas, thus creating new applications.

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Publication date: November 18, 2025

Cryptoassets, of which a token is a type, are digital representations of value or rights that can be transferred and stored electronically using distributed ledger technology or similar technologies. There are three types of tokens: payment or e-money tokens, which serve as a medium of exchange or a store of value; investment tokens, which perform functions analogous to securities; and utility tokens, which provide access to services or products, somewhat similar to vouchers. There are also hybrid tokens, for example, combining the features of cryptocurrencies and real-world assets. These tokens operate by embodying the value of a specific real-world asset and combining it with the flexibility and efficiency of cryptocurrencies. The goal is to provide access to blockchain technology while simultaneously providing a solid link to the underlying tangible asset.

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