On 5 October 2026, a new tax ruling clarified that fuel and driver salary costs for school buses operated by private educational institutions qualify as productive business expenses under Article 22 of Law 4172/2013 (Income Tax Code). The decision confirms deductibility even when the transport service is not invoiced separately but is included in tuition fees. This interpretation aligns with the principle that expenses incurred wholly and exclusively for business purposes are deductible, regardless of invoicing structure.
Key Takeaways
- Expanded Deductibility Scope: The ruling extends deductibility to embedded transport costs, provided the school can demonstrate the expenses are directly linked to its educational activity.
- Documentation Requirements: Schools must maintain detailed internal records allocating fuel and payroll costs to the transport function, even absent separate invoices.
- Audit Defense: The decision strengthens taxpayer position in potential audits by establishing a precedent for bundled service cost allocation.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement