Ryczałt and the manufacture of excise-taxed goods — the exception for renewable electricity

Ryczałt and the manufacture of excise-taxed goods

If you manufacture goods subject to excise duty, you cannot use ryczałt, Poland’s lump-sum tax on recorded revenue. The exception concerns the generation of electricity from renewable energy sources. This rule is set out in the Ministry of Finance guidance on ryczałt taxation.

This guide covers only that exclusion and its exception. It does not discuss the revenue limit or the rules concerning trade in car parts.

How narrow is the renewable energy exception?

Under this rule, the following elements matter together: generation, electricity and renewable energy sources. The exception must not be read as covering all goods associated with renewable energy, trade in excise-taxed goods or every type of energy business.

Merely referring to renewable energy is not enough to apply this exception. Its wording specifically concerns the generation of electricity from renewable energy sources. This guide does not determine whether a particular energy source meets that description.

An exception to one exclusion does not confirm that all conditions for ryczałt are met. It therefore does not guarantee eligibility for this form of taxation. This distinction reflects the narrow scope of the Ministry of Finance rule discussed here.

Expanding your business — the Ministry of Finance warning

The Ministry of Finance warns: “By expanding your business to include activities excluded from ryczałt taxation, you will lose the right to this form of taxation.” This is an English translation of the warning in the Ministry’s ryczałt guidance.

For the exclusion discussed here, its full wording must be preserved: it concerns manufacturing goods subject to excise duty, except for generating electricity from renewable energy sources. This guide does not determine the date on which eligibility for ryczałt is lost or how to account for the consequences.

Optional organization of information

For organizational purposes, you can prepare your own list of:

• goods actually manufactured in your business;
• brief descriptions of what you manufacture, distinguishing manufacturing from trading;
• planned changes to manufacturing activities;
• questions requiring clarification, without independently settling the classification of a product or energy source.

This is solely an optional organizational recommendation, not a legal obligation or confirmation of eligibility for ryczałt.

Scope of this guide

We do not classify particular goods as subject to excise duty or assess particular energy sources. Ryczałt and excise duty rates, excise exemptions, registrations, licences, deadlines, corrections, VAT and individual calculations are outside this guide’s scope.