Polish Supreme Administrative Court rules managerial consulting services ineligible for lump-sum taxation

The Supreme Administrative Court (NSA) ruled that B2B consulting contracts involving managerial authority, such as contract execution and company representation, constitute personally performed activities. This classification prohibits the application of lump-sum tax regimes, requiring these services to be taxed under standard income tax rules. The ruling clarifies the tax treatment of hybrid consulting roles, potentially increasing the tax burden for independent contractors performing executive functions.