Multiple Lump-Sum Tax Rates in One Sole Proprietorship: Separating and Documenting Revenue

A practical guide to recording revenue subject to different Polish lump-sum tax rates and handling uncertain service classifications.

A single Polish sole proprietorship, or JDG, may earn revenue subject to different lump-sum tax rates. In that case, the lump-sum tax is calculated at the rate applicable to the revenue from each type of activity. The revenue records must also make it possible to determine the revenue attributable to each type of activity, as explained by the Ministry of Finance in Settlement of revenue taxed under the lump-sum regime.

The legal requirement is therefore to separate the relevant revenue correctly in the records. The service catalogue, detailed invoice descriptions, and documentation files discussed below are optional organizational measures. They can help demonstrate why a particular amount was allocated to a given type of activity and rate, but the cited official materials do not establish them as separate universal obligations.

1. Start with a catalogue of the services actually performed

Consider preparing an internal list of the services you actually sell. For each service, you can record:

the exact activities performed,
the result delivered to the client,
typical contractual provisions,
the description normally used on invoices,
the adopted lump-sum rate and the basis for applying it,
the PKWiU grouping, where classification is relevant to determining the rate for that service,
documents or explanations supporting the allocation.

Do not assume that one general PKWiU code applies to the entire business merely because all services are performed by the same person, supplied to the same client, or associated with the same broad industry. The Ministry of Finance states that, as a rule, the correct lump-sum rate for service activity is determined using the PKWiU symbol applicable to the particular service. This calls for an analysis of each service rather than automatically applying one code across the whole JDG. See PIT rates and limits.

2. Make it possible to allocate amounts to each type of activity

If one billing document covers distinct services subject to different rates, showing them as separate invoice items may be a practical solution. Organizational descriptions could include:

“Service A — scope consistent with the acceptance report,”
“Service B — period and scope consistent with the specification.”

Separate invoice items are not presented here as a universal legal requirement. What matters is that the documentation as a whole makes it possible to allocate a particular amount reliably to the correct type of activity and rate. Relevant supporting materials may include the agreement, order, work specification, performance report, or acceptance report.

If the client pays one price for a package, first determine what is actually being supplied. Any allocation of the fee should reflect the economic and contractual scope of the supplies rather than being created solely to apply a different tax rate.

3. Keep records divided by type of revenue

Under the lump-sum regime, tax applies to revenue from non-agricultural business activity without reducing that revenue by the expenses incurred to earn it. Where several rates apply, the records must make it possible to determine the revenue from each type of activity. The Ministry of Finance describes both rules in Settlement of revenue taxed under the lump-sum regime.

An auxiliary register may include the following fields:

date on which the revenue was earned,
document number,
category or type of activity,
revenue amount,
rate applied,
basis for the allocation,
notes concerning corrections or related documents.

Calculation example only

Assume that a proper analysis of two distinct types of activity resulted in the following rates being applied:

Service A: document FV/09/01; revenue of PLN 10,000; rate of 12%; allocation supported by the Service A file and acceptance report.
Service B: document FV/09/02; revenue of PLN 4,000; rate of 8.5%; allocation supported by the Service B file and a separate contractual scope.

Calculation:

PLN 10,000 × 12% = PLN 1,200,
PLN 4,000 × 8.5% = PLN 340,
total before any applicable deductions or other reliefs: PLN 1,540.

The rates in this example are assumptions used only to illustrate the calculation. They do not determine how a particular service is taxed merely because it has a given contractual or invoice name. Where different types of activity are subject to different rates, do not apply one averaged rate to the combined revenue.

4. Reconcile the documentation with the revenue records

As an organizational measure, it is useful to check consistency across three levels:

Commercial documentation — the agreement, order, or specification describes the actual scope of the supply.
Sales documentation — the description makes it possible to link the amount due to the activities performed.
Revenue records — the amount is allocated to the correct type of activity and rate.

Once a month, or before a quarterly settlement, you can compare the totals in the sales documents, revenue records, and lump-sum tax calculation. After issuing a correction, also check whether the allocation of revenue to a type of activity or rate must be changed.

5. What to do when the service classification is uncertain

First describe the service without relying on marketing terminology. Specify:

the activities performed,
the result of the service,
how the service is performed,
the recipient of the service,
any ancillary elements,
activities that are not included.

You can then check possible groupings using the GUS classification search tool. The Statistical Office in Łódź states that this tool covers, among other things, groupings of goods and services under PKWiU. The relevant information is available on the page of the Classification and Nomenclature Centre of the Statistical Office in Łódź.

If at least two possible groupings remain, a practical sequence of steps is:

prepare a detailed description of each service variant you actually offer;
attach materials that help establish the nature of the service, such as a scope of work, agreement, or specification;
use the procedure of the Classification and Nomenclature Centre for requests concerning goods or services under PKWiU 2015;
state the purpose of the request, for example determining a PKWiU 2015 classification for income-tax purposes;
retain the request, its attachments, and the response received;
after establishing the grouping, separately compare it with the tax provision governing the applicable lump-sum rate.

The Statistical Office in Łódź explains that requests for classification information concerning goods or services under PKWiU 2015, when submitted for purposes other than the binding procedures listed on its website, should be directed to the Classification and Nomenclature Centre. It also asks applicants to state the purpose of the request.

6. Optional documentation file

For each material type of revenue, you may keep an auxiliary documentation file containing:

a service sheet describing the activities performed,
the basis for applying the rate,
the adopted grouping and justification, where classification is relevant to determining the rate,
a standard invoice-item description,
sample agreements, specifications, and acceptance reports,
correspondence concerning classification,
the GUS response, if classification information was requested,
a history of changes to the service scope.

This is an organizational recommendation, not a closed list of legally required documents. Update the service sheet when the activities performed change. A previously used service name should not replace an analysis of the new or modified scope.

7. Checklist before settling a month or quarter

Has every amount been allocated to a specific type of activity?
Do the revenue records make it possible to determine separately the revenue subject to each rate?
Do the commercial and sales documents provide a reliable basis for reconstructing the allocation of each amount?
Does the rate applied correspond to the activities actually performed?
Has the PKWiU grouping been checked where it is relevant to determining the rate?
Have corrections been entered in the appropriate revenue category?
Has any classification uncertainty been resolved before the rate is used in subsequent settlements?