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Refusal to issue an "Individual Recommendation" regarding one of the Company's questions

In regard of the Current Report 23/2019, LiveChat Software S.A. informs that the Director of the National Treasury Information refused to issue an "Individual Recommendation" regarding the question: "Does the factual way of keeping the records presented by the Company meet the requirements referred to in art. 24e of the CIT Act? "

In the comment, the Authority stated that "it does not deny that the Applicant's acceptance of accounting records in a manner enabling the Company to divide individual items of income calculation under IP BOX - and thus revenues and costs attributable to each qualified intellectual property right, will allow to avoid unauthorized deduction of costs incurred, in part in which they do not relate to qualified intellectual property law, and under the Corporate Income Tax Act, there are no contraindications to using the accounting records of qualified intellectual property rights in order to link given costs or revenues to a given activity. However, analyzing the issue presented to the Authority the decision in question number 3 in the context of the cited principles of interpretive proceedings leads to the conclusion that it cannot be subject to analysis and assessment in such proceedings. "