Taxpayers have started to receive tax rulings on the robotization relief in income taxes.

The relief, which was introduced to last from 2022 to 2026, has been in force since 1 January 2022. It applies to purchases of brand new industrial robots and certain related equipment and software.

The allowance permits taxpayers to make additional deductions (i.e. in addition to treating the expenses as regular tax costs) from net income for 50% of their robotization expenses.

Taxpayers came to raise plenty of practical inquiries as to the scope of the allowance and how it should be accounted for.

Following the inquiries, the Director of National Revenue Information confirmed in three rulings (ref. 0111-KDIB1-1.4010.212.2022.4.BK, 0111-KDIB1-1.4010.221.2022.2.AW and 0111-KDIB1-2.4010.129.2022.2.AW) that one way in which the relief can be used is by making deductions from net income for 50% of depreciation charges made from 2022 to 2026 on industrial robots purchased even before 1 January 2022.

In another ruling the authority held that expenses eligible for the relief must concern software strictly related to robot’s commissioning and operation but not to overall production management or scheduling (ruling ref. 0111-KDIB1-2.4010.9.2022.1.AW).

Given its structure and the recent rulings, the robotization allowance can provide important relief for innovative companies alongside R&D relief, prototype relief and IP Box. However, preparation is needed to use it safely, including the following steps:

  • review your industrial machines to check if they can be treated as industrial robots;
  • review your related equipment and software expenses in light of the statutory list of expenses eligible for the relief;
  • work out how to account for and document your robotization relief;
  • where reasonable, secure a private tax ruling before annual CIT return date.

If this issue pertains to your business and you are interested in our assistance, please contact us.

This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.