This article discusses international and EU regimes providing incentives to finance cultural undertakings. It attempts to identify the scope of the concept of “cultural heritage”, which today embraces a wide range of expressions of human creativity and produces significant turnover. The author demonstrates that the current forms of public funding are insufficient to ensure adequate protection of cultural heritage and, due to inputs coming from EU institutions, the need to adopt tax breaks to stimulate funding from the private sector has become critical in recent years.