A corporate income tax (CIT) relief was introduced as of 1 January 2022 called robotization allowance.
Article 38eb(1) of the CIT Act allows taxpayers to deduct from income up to 50% of tax costs incurred on the robotization of their enterprises (industrial robots and peripherals).
The deduction is available for tax costs incurred on robotization as of the first day of the tax year begun in 2022 and until the last day of the tax year begun in 2026.
The law has caused uncertainty as to whether the relief is applicable to industrial robots and peripherals purchased before 1 January 2022 and depreciated after that date.
The issue has been the subject of private tax rulings, as such those dated 9 February 2023, ref. 0111-KDIB1-1.4010.800.2022.2.AW, 30 September 2022, ref. 0111-KDIB2-1.4010.415.2022.2.AR, and 31 August 2022, ref. 0111-KDIB1-1.4010.221.2022.2.AW, where the ruling authority confirmed that the relief applies also to depreciation charges made in 2022-2026 on industrial robots or peripherals brought into service before 2022.
It is advisable to ensure that use of the relief in a particular case, especially for industrial robots purchased before 1 January 2022, is secured via a private tax ruling.
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.