2024-09-16

Robotics Tax Relief – Is It for All Entrepreneurs?

Entrepreneurs generating revenue from business activities can take advantage of the robotics tax relief until the end of 2026. This incentive allows businesses to deduct 50% of specific expenses from their taxable income, in addition to already recognizing them as tax-deductible costs. This effectively enables companies to deduct 150% of eligible expenses.

What Costs Can Be Deducted Under the Robotics Tax Relief?

Taxpayers utilizing this relief can deduct expenses related to:

  • The purchase of brand-new:

    • Industrial robots

    • Peripheral machines and devices functionally related to industrial robots

    • Machines, equipment, and other items functionally linked to industrial robots, including sensors, controllers, relays, safety locks, physical barriers (fences, covers), and optoelectronic protective devices (light curtains, area scanners)

    • Machines, devices, or systems for remote management, diagnostics, monitoring, or servicing of industrial robots, including sensors and cameras

    • Human-machine interaction devices for industrial robots

  • The acquisition of intangible assets necessary for the correct implementation and operation of industrial robots and the above-mentioned fixed assets

  • Training services related to industrial robots and the relevant fixed assets or intangible assets

  • Leasing fees for industrial robots and the eligible fixed assets, provided that ownership is transferred to the lessee after the basic lease period ends

Robotics Tax Relief for All and Any Machine?

To qualify for the tax relief, a purchased machine must have an “industrial application.”

According to tax authorities, “industrial application” means use strictly in the production (manufacturing) of goods. Therefore, only machines that are directly related to manufacturing processes—such as those used in production lines—qualify as industrial robots (as per individual tax rulings issued by the Director of the National Tax Information on April 2, 2024, ref. 0111-KDIB1-2.4010.83.2024.1.MK, and June 29, 2023, ref. 0111-KDIB1-3.4010.162.2023.2.JG).

Administrative courts confirm that “industrial application” should be understood as activities involving production using machines and other technical devices. This means that only entities engaged in manufacturing qualify, whereas businesses involved in retail or distribution are excluded (e.g., ruling of the Voivodeship Administrative Court in Łódź, December 6, 2023, ref. I SA/Łd 801/23).

Expansion of Eligible Businesses for Robotics Tax Relief

However, administrative courts have taken a more liberal approach, broadening the interpretation of “industrial application.” They argue that the relief should also apply to machines used by manufacturing entities that do not directly participate in the production process itself—such as those used for storage, sorting, logistics, or packaging (e.g., ruling of the Voivodeship Administrative Court in Kraków, April 23, 2024).

Conclusion

The robotics tax relief allows businesses to deduct up to 150% of eligible expenses. However, in order to benefit from it, taxpayers must first determine whether their investment qualifies under the definition of “industrial application.” Tax advisors at ATA Tax are available to assist with this evaluation.

For more details on the robotics tax relief, please visit the official government website: Ulga na robotyzację (podatki.gov.pl).

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