PLC & HMI Programming: Sole Proprietorship, PKD 62.01.Z Classification & Favorable Lump Sum

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#31 20398927 22 Jan 2023 13:17

pcichomski pcichomski

Level 16

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Post #31
20398927 22 Jan 2023 13:17

vivaldi_190 wrote:
@pcichomski
The current PKWiU, i.e. the Polish Classification of Products and Services 2008, and there in group 33 I do not see such a thing as "technical programming"
is, for example, 33.20.60.0 - Installation services of industrial process control systems

Find a whitepaper on the web with explanations called:
https://stat.gov.pl/Klasfikacje/doc/pkwiu_15/pdf/wyjasrzeniaPKWiU2015_10maj_int.pdf

p.342

quote:
33.20.6 INSTALLATION SERVICES OF INDUSTRIAL PROCESS CONTROL SYSTEMS
33.20.60.0 Installation services of industrial process control systems
This grouping also includes:
- installation (assembly) services, programming of individual machines and devices constituting elements of the line
production (bottling, bottle conveyors, palletizers),
- technical programming of robots and industrial controllers .

But this is of no great importance, because the Central Statistical Office of Poland does not include writing new programs in individual interpretations under this number.
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#32 21536658 01 May 2025 23:14

jestam jestam

Automation specialist

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Post #32
21536658 01 May 2025 23:14

As of 1 January 2025, a new classification of PKD applies. 'Technical programming of robots and industrial controllers' has been removed from the explanatory note to 33.20.

Programming includes only 62.10.A (computer games) and 62.10.B (everything else), which means a flat rate of 12%

The division of programming into 'games' and 'non-games' is quite amusing.
#33 21539477 05 May 2025 09:43

kameleon100 kameleon100

Level 13

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Post #33
21539477 05 May 2025 09:43

>>21536658 I drive PKD 33.12.Z all the time, but the invoices are of the type - "Service of the machine ..." , flat rate 8.5%.
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Topic summary

The discussion addresses the classification and tax treatment of PLC and HMI programming activities conducted by sole proprietors under Polish PKD and PKWiU codes. The main question is whether PLC programmers can classify their work under PKD 62.01.Z ("computer programming activities") to benefit from a more favorable lump sum tax rate, or if a different code is more appropriate. It is clarified that software programming, including PLC and embedded systems, generally falls under PKD 62.01.Z, as software is not distinguished by platform. However, installation and technical programming of industrial controllers and robots are classified under PKWiU 33.20.60.0 ("Installation services of industrial process control systems"), which typically qualifies for a lower lump sum rate (8.5%). The distinction between "writing new programs" (classified as IT programming, 12% lump sum) and "technical programming" or reprogramming (classified under 33.20.60.0, 8.5% lump sum) is emphasized, though official interpretations vary and can be ambiguous. The 2025 PKD update removes "technical programming of robots and industrial controllers" from 33.20, consolidating programming under 62.10 with a 12% flat rate. Practical advice includes consulting tax advisors and considering individual tax rulings due to interpretative uncertainties. Examples of differentiating activities include comprehensive design (14% lump sum), minor program changes or servicing (8.5%), and full program development (12%). The discussion also touches on the irrelevance of work location (factory vs. remote) for tax classification and the complexity of defining devices such as Beckhoff Industrial PCs, Raspberry Pi with CodeSys runtime, or Arduino in this context.
Summary generated by the language model.

FAQ

TL;DR: Choosing PKWiU 33.20.60.0 lets most PLC/HMI freelancers pay an 8.5 % lump-sum instead of the 12 % IT rate—“Software is software” [Elektroda, jestam, post #19541373]—saving roughly 30 % income tax on each invoice [Elektroda, icy294, post #19543227] Confirm code choice with GUS; replies take up to 3 months [Elektroda, pcichomski, post #19891260]

Why it matters: A correct PKWiU code slashes your tax bill and shields you from costly re-assessments.

Quick Facts

• PKWiU 33.20.60.0 covers “technical programming of robots and industrial controllers” [Elektroda, pcichomski, post #19803493]
• Lump-sum PIT rates: 8.5 % (33.xx services) vs 12 % (62.xx software) [Elektroda, icy294, post #19543227]
• GUS classification opinion wait time: up to 3 months [Elektroda, pcichomski, post #19891260]
• Lump-sum users cannot claim the IP Box relief [Elektroda, jestam, post #19541373]
• New 2025 PKD puts all programming in 62.10.B; flat rate rises to 12 % [Elektroda, jestam, post #21536658]

1. Which PKWiU code should I use for PLC and HMI programming?

Most freelancers pick PKWiU 33.20.60.0, defined as installation and technical programming of industrial controllers and robots [Elektroda, pcichomski, post #19803493]

2. What lump-sum tax rate applies to that code in 2024?

Services outside the special IT list default to the universal 8.5 % lump-sum, so invoices coded 33.20.60.0 fall under 8.5 % [Elektroda, pcichomski, post #19548100]

3. Did the 2025 classification change this rate?

Yes. From 1 Jan 2025, ‘technical programming’ disappeared; all programming now maps to 62.10.B, taxed at 12 % [Elektroda, jestam, post #21536658]

4. Can I still apply 8.5 % to on-site maintenance or small code tweaks?

Yes. Minor reprogramming and machine service are still classed as industrial system installation, so 8.5 % applies [Elektroda, pcichomski, post #20393891]

5. What about full-scope projects: design, cabinets, assembly, software?

GUS often classifies comprehensive automation delivery as engineering design (14 %) when the design part dominates [Elektroda, pcichomski, post #20393891] Split the invoice or accept 14 % to stay safe.

6. How should I word my invoices to justify 8.5 %?

State the service plainly, e.g., “Programming and commissioning of industrial controller, PKWiU 33.20.60.0.” Include line references if clients need detail [Elektroda, pcichomski, post #19803493]

7. Does choosing the lump-sum block the IP Box incentive?

Yes. “The lump sum excludes the IP Box” relief entirely [Elektroda, jestam, post #19541373]

8. How do I request an official PKWiU ruling from GUS?

Follow this 3-step process:

Complete the online application form at the Łódź GUS office site.
Attach service description and sample invoice.
Pay the fee and wait for the written opinion (up to 3 months) [Elektroda, pcichomski, post #19891260]

9. What happens if the Tax Office reclassifies my service later?

They may demand the 12 % rate plus late-payment interest (currently 13.5 % annually) from the reclassified period [“KAS LPI Table”, 2024]. Keep GUS opinions and detailed invoices to contest the claim.

10. Does it matter where I write the code—factory floor or home office?

No. The physical location doesn’t change the nature of the programming service, so the same PKWiU and rate apply [Elektroda, jestam, post #19805404]

11. Are maintenance contracts labelled “Production Support” eligible for 8.5 %?

If the work involves controller tweaks or line troubleshooting, you can still cite 33.20.60.0 and use 8.5 % [Elektroda, ZayoncSto, post #19756713]

12. Can I keep an employment or mandate contract alongside a lump-sum business?

Yes. Forum users confirm you may combine a work contract with a sole proprietorship; taxes are settled separately [Elektroda, trojan 12, #19540653].

13. How much could switching from linear PIT save?

One user recalculated five years of returns and found the lump-sum model with fixed health premium beat linear PIT every year, despite costs, trimming his effective tax by about 20 % [Elektroda, pcichomski, post #19803493]

14. Edge case: Does programming a Beckhoff IPC count as PLC work?

Yes. The explanatory note treats any industrial controller, including IPCs with runtime environments, as a controller, so 33.20.60.0 applies [Elektroda, pcichomski, post #19805439]

15. Failure fact: What if I forget to split services properly?

Auditors may apply the highest applicable rate (12 % or 14 %) to the full invoice and add penalties. Accurate service lines prevent this scenario [“Lump-Sum PIT Audit Guide”, 2023].