Poland proposes extending robotisation relief and ending expansion deduction

Robotisation relief would run for another decade

The bill would keep the 50% additional deduction for qualifying robotisation costs, moving the end date in Corporate Income Tax Act Article 38eb(5) and Personal Income Tax Act Article 52jb(5) from tax years beginning in 2026 to those beginning in 2036. New Articles 38eb(2a) and 52jb(2a) would also settle a timing point for depreciable fixed and intangible assets: the qualifying cost would be the tax depreciation charged to deductible costs in the year, rather than the acquisition price.^[2][3][4]

The environmental restriction would remain for legacy costs

For costs incurred under the extended regime, the bill would repeal the current environmental exclusions in Articles 38eb(5a) and 52jb(5a), which disallow relief for specified emissions-trading, fossil-fuel and waste activities. That repeal would be prospective. Bill Article 7 preserves the existing restriction for individual-business costs incurred through 2026 and corporate costs incurred through a tax year that began in 2026.^[2][3][4]

Expansion expenditure would lose its additional deduction

Bill Articles 1(2) and 2(1) would repeal the expansion deduction in Personal Income Tax Act Article 26gb and Corporate Income Tax Act Article 18eb. Those provisions currently allow qualifying promotion, trade-fair, packaging, certification and tender costs to be deducted again, up to PLN1 million annually, subject to the statutory sales-growth conditions. Article 6 preserves the existing rules for eligible costs incurred before 1 January 2027.^[2][3][4]

The transition turns on income date and tax year

The proposed changes would generally apply to income or revenue earned from 1 January 2027. A corporate taxpayer whose tax year starts before that date and ends afterwards would continue under the existing CIT rules until that year closes. Multinational groups with Polish manufacturing operations should therefore separate pre-2027 and later expansion expenditure, model depreciation-based robotisation claims and retain environmental-eligibility evidence for legacy costs. The measure remains a bill and has not been enacted.^[1][2]