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

pcichomski 13434 32
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  • #1 19540549
    pcichomski
    Level 16  
    I have a question regarding the upcoming changes:

    Can a PLC programmer operating as a Sole Proprietorship and dealing almost exclusively with writing programs for PLC and HMI on commission subsume his activity under PKD 62.01.Z for "computer" programmers and use a more favorable lump sum than a straight line? Or maybe a different code?
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  • #3 19541186
    pcichomski
    Level 16  
    I looked carefully, but I'm still not clear, because the records are general, and the 62.xxx group is mostly used by PC or Android programmers.
    Do any of your fellow PLC programmers have any personal experience in this matter?
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  • #5 19541373
    jestam
    Automation specialist
    "PKD 62.01.Z - Activities related to software"

    There is no distinction between "computer" and some other (PLC, embedded/uC, robotic or other). Software is software. Besides, today's PLCs have sockets, database clients and Java runtime ;-)

    62.02Z, 62.03Z and 62.09Z are also suitable, especially if, in addition to programming, you sometimes sell controllers or run or service them.

    The lump sum excludes the IP Box - by the way, does any of your colleagues use this relief?
  • Helpful post
    #6 19543227
    icy294
    Level 2  
    And it is not a coincidence that PLC programming comes under 33.20.6, i.e. "Industrial process control system installation services", because in the document "EXPLANATIONS to the Polish Classification of Products and Services (PKWiU 2015)" it is added that it also includes "technical programming robots and industrial controllers. So, due to the fact that this PKWiU is not mentioned in the lump sum act, the flat rate of 8.5% applies?
  • #7 19543971
    pcichomski
    Level 16  
    icy294 wrote:
    And it is not a coincidence that PLC programming comes under 33.20.6, i.e. "Industrial process control system installation services", because in the document "EXPLANATIONS to the Polish Classification of Products and Services (PKWiU 2015)" it is added that it also includes "technical programming robots and industrial controllers. So, due to the fact that this PKWiU is not mentioned in the lump sum act, the flat rate of 8.5% applies?


    I think you're right. I reviewed this:
    https://podatki.gazetaprawna.pl/artykuly/8049390,ryczalt-pit-przychod-ewidencjonowany.html


    and it seems to agree with what you say. That is even better than the 12% lump sum promised to developers.
  • #8 19544169
    jestam
    Automation specialist
    33.20.6
    Quote:

    This grouping also includes:
    - services of installation (assembly), programming of individual machines and devices constituting elements of the line
    production (bottling, bottle conveyors, palletizers),
    - technical programming of robots and industrial controllers.

    So that it does not turn out that HMI / SCADA no longer catches on :-(
  • #9 19544348
    icy294
    Level 2  
    HMI can rather be pulled under this:

    - installation (assembly) services, programming individual machines and devices that are part of the line
    production
    (bottlers, bottle conveyors, palletizers),

    drive configuration, etc.

    To be sure, it would be good to consult with a tax advisor, because it is still a matter of interpretation.
  • #10 19544439
    Anonymous
    Level 1  
  • #11 19544600
    jestam
    Automation specialist
    After all, a tax advisor is not responsible for anything. When there are doubts, it remains to apply for an individual interpretation, but this has the disadvantage that it attracts attention and you can fall into the list to be checked.

    I have some doubts here, because "a device that is part of the production line" can be a computer; that is the same as 62.01 and there the lump sum would be higher. On the other hand, what is important on the invoice - if the Xxx machine software is developed on the Yyy line, it may be ok.

    The question is what about jobs that clearly don't fit under 33.20.6 - don't do it at all?
  • #12 19548100
    pcichomski
    Level 16  
    All in all, things have become clear:

    Since currently (since this year) there is a closed catalog of services/professions that do not qualify for a lump sum (excluded from the lump sum, have nothing to do with automation or computers), all others can be settled in the form of a registered lump sum.
    In addition, there is a second directory that assigns different flat rates to specific PKWiU numbers (only some, e.g. for IT). For other services outside this catalog (and not being one of the services from the catalog of exclusions) the rate is 8.5%. Since there are no 33..... services in the detailed catalogue, these services are subject to the "universal" flat rate of 8.5%.

    Speaking of advisors: even at the beginning, mine didn't quite understand what industrial automation was.
  • #13 19756713
    ZayoncSto
    Level 3  
    pcichomski wrote:

    Speaking of advisors: even at the beginning, mine didn't quite understand what industrial automation was.

    Exactly, that's why we're talking here, because maybe someone already has it well figured out.

    I have a different kind of doubt. Sometimes our activity is actually writing a program for the controller from start to finish, on the line, and it seems to come close to 8.5%, but what about, for example, when you are hired to maintain traffic, you change little in plc and you will get an invoice " Production Support"?

    Have any of you made any tax decisions yet? Thanks in advance for your feedback and best regards
  • #14 19803355
    owerel209
    Level 8  
    Hello,
    I am facing a similar dilemma. I understand that the possibility of using the 8.5% lump sum for programming and commissioning PLC, HMI, robots has been confirmed?
    Has anyone already made that decision?
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  • #15 19803493
    pcichomski
    Level 16  
    Hello,
    Since I receive a lot of private messages regarding the transition to a lump sum and the application of the 8.5% rate, I will answer here as I see it, what I know for sure and what I think.

    - I am switching to a lump sum, because I have a relatively high margin (low costs compared to income). I calculated my income and costs from the last 5 years in this respect, and each time when recalculating them using the rules of the "new shaft", it is better for me to switch to a flat rate of up to 15%, but with a fixed health insurance premium, than to stay on the straight line. I recommend this calculation to everyone. You know your pitas from previous years, so a few hours of work brighten up the picture.

    - evidently PLC and robot programming as well as all installation works related to automation have the number PKWiU=33.20.60.0. (there's a post about it somewhere above). Please search the link below for this code.
    https://stat.gov.pl/Klasfikacje/doc/pkwiu_15/pdf/wyjasrzeniaPKWiU2015_10maj_int.pdf

    - In the PIT Act in art. on a flat rate for any rates other than 8.5% this group is not listed (not even the initial more general digits of the code). According to the information obtained from the Tax Office, if this is the case (and you are not in the group that excludes the lump sum at all - but this does not apply to automatic machines), it means that the rate of 8.5% applies to such invoices. Just in case, for this type of services, it is worth formulating the content of the invoice in a similar way (but of course truthfully). Link to the law below. Look carefully from Art.2.1 (p.11=.
    https://dziennikustaw.gov.pl/D2021000199301.pdf

    - The Tax Office informed me that if I have a problem with assigning PKWiU to other services (e.g. drawing a diagram in Eplan, overall execution of the order, including cabinet fabrication, assembly, commissioning) then I should ask the Central Statistical Office a question. Unfortunately, this is a paid service. I asked interesting questions and I am waiting for an answer. But that can take months. For now, I will use the rate of 8.5%, because all this is related to 33.20.60.0. Otherwise, you just have to pay the tax up to the correct rate. Link to the application below:
    https://lodz.stat.gov.pl/osrodki/osrodek-klas...menklatur-urzedu-statyczny-w-lodzi/formularz/

    I asked about:
    - drawing diagrams
    - servicing devices, machines, lines in the field of automation
    - comprehensive implementation (on one invoice) (delivery of components, design, fabrication, assembly, programming, etc.)

    If I know anything, I will write.

    As for the HMI, I pull it up from the PLC, because for TIA it's pretty much the same programming tool.

    NOTE: I take no responsibility for your decisions. I have taken these, I am more or less convinced of them, but I suggest you review the laws carefully and rethink the matter yourself.
  • #16 19803507
    owerel209
    Level 8  
    Thank you for your answer. As compensation, I will share the information from the Central Statistical Office that I received when asked about the type of PKD when designing electrical cabinets. PLC & HMI Programming: Sole Proprietorship, PKD 62.01.Z Classification & Favorable Lump Sum
  • #17 19803658
    pcichomski
    Level 16  
    owerel209 wrote:
    Thank you for your answer. As compensation, I will share the information from the Central Statistical Office that I received when asked about the type of PKD when designing electrical cabinets. PLC & HMI Programming: Sole Proprietorship, PKD 62.01.Z Classification & Favorable Lump Sum


    So 14% for such services:
    article 12.1
  • #18 19803670
    owerel209
    Level 8  
    Wherein
    Quote:
    Currently, a freelance profession is understood as a non-agricultural business activity performed personally, e.g. by doctors and dentists without employment on the basis of employment contracts, mandate contracts, contracts for specific work and others contracts of a similar nature who perform activities related to the essence of a given profession.


    I wonder how it is for people on b2b.
  • #19 19805191
    ZayoncSto
    Level 3  
    owerel209 wrote:
    Hello,
    I am facing a similar dilemma. I understand that the possibility of using the 8.5% lump sum for programming and commissioning PLC, hmi, robots has been confirmed?
    Has anyone already made that decision?


    Well, I will try. I’m at the factory - I settle for 8.5%, Offline - I settle for 12%. If anyone finds out, I will support myself with the explanation of PKWiU, which someone posted above. In the worst case, they make you pay 12%, which in my case will more or less cover the ruler, but I will still be much ahead on the health premium
  • #20 19805250
    pcichomski
    Level 16  
    ZayoncSto wrote:
    owerel209 wrote:
    Hello,
    I am facing a similar dilemma. I understand that the possibility of using the 8.5% lump sum for programming and commissioning PLC, hmi, robots has been confirmed?
    Has anyone already made that decision?


    Well, I will try. I'm at the factory - I settle for 8.5%, Offline - I settle for 12%. If anyone finds out, I will support myself with the explanation of PKWiU, which someone posted above. In the worst case, they make you pay 12%, which in my case will more or less cover the ruler, but I will still be much ahead on the health premium


    And why do you differentiate online and offline? And where does the 12% rate for offline come from? What PKWiU number do you use on the invoice for this offline one?
  • #21 19805404
    jestam
    Automation specialist
    That 12% is probably 62.xx

    The distinction between working at home/office and working in a factory is unnecessary in my opinion. If programming a PLC requires 2 weeks, what difference does it make if I spend it with a laptop on my knees in the hall next to the wardrobe, or comfortably at my desk, uploading a ready program in 5 minutes? The same work is done.

    I am convinced by the argumentation of Col. @pcichomski. However, I have doubts where PLC programming ends at 8.5% and another type of programming begins at 12%.

    Is the Industrial PC from Beckhoff a PLC? PC with CodeSys runtime and remote I/O? Raspberry with CodeSys runtime? Valve terminal or servo with CodeSys runtime? PC + I/O or raspberry from another manufacturer's runtime? Or your own runtime? Your own library of PLC-typical functions? A PC with I/O with a program in a language other than LAD/ST/SFC, but dedicated to controlling a machine or part of a production line? Arduino with control program? Any programmable device dedicated to machine control? Which program is 90% used to control the machine? 50%? 10%?

    Asking for such details of the Central Statistical Office may not be the best idea.
  • #22 19805439
    pcichomski
    Level 16  
    jestam wrote:
    That 12% is probably 62.xx

    The distinction between working at home/office and working in a factory is unnecessary in my opinion. If programming a PLC requires 2 weeks, what difference does it make if I spend it with a laptop on my knees in the hall next to the wardrobe, or comfortably at my desk, uploading a ready program in 5 minutes? The same work is done.

    I am convinced by the argumentation of Col. @pcichomski. However, I have doubts where PLC programming ends at 8.5% and another type of programming begins at 12%.

    Is the Industrial PC from Beckhoff a PLC? PC with CodeSys runtime and remote I/O? Raspberry with CodeSys runtime? Valve terminal or servo with CodeSys runtime? PC + I/O or raspberry from another manufacturer's runtime? Or your own runtime? Your own library of PLC-typical functions? A PC with I/O with a program in a language other than LAD/ST/SFC, but dedicated to controlling a machine or part of a production line? Arduino with control program? Any programmable device dedicated to machine control? Which program is 90% used to control the machine? 50%? 10%?

    Asking for such details of the Central Statistical Office may not be the best idea.


    In the explanations of the Central Statistical Office to 33.20.60.0 it says: "technical programming of robots and industrial controllers", so I would stick to it without going into details whether it is a canonical PLC or a PC. A servo controller or a PC with a machine program is also a controller.
  • #23 19891079
    vivaldi_190
    Level 10  
    Hello colleagues
    Question to @pcichomski did you send info about your questions:
    "I asked about:
    - drawing diagrams
    - servicing devices, machines, lines in the field of automation
    - comprehensive implementation (on one invoice) (delivery of components, design, fabrication, assembly, programming, etc.)
    ?
  • #24 19891260
    pcichomski
    Level 16  
    vivaldi_190 wrote:
    Hello colleagues
    Question to @pcichomski did you send info about your questions:
    "I asked about:
    - drawing diagrams
    - servicing devices, machines, lines in the field of automation
    - comprehensive implementation (on one invoice) (delivery of components, design, fabrication, assembly, programming, etc.)
    ?


    I'm still waiting. Supposedly up to 3 months.
  • #25 19980213
    Tomus-Gaw
    Level 1  
    @pcichomski And did you get an answer from the office yet?
  • #26 20393763
    vivaldi_190
    Level 10  
    I repeat the question to @pcichomski did you get information about your questions
    "I asked about:
    - drawing diagrams
    - servicing devices, machines, lines in the field of automation
    - comprehensive implementation (on one invoice) (delivery of components, design, fabrication, assembly, programming, etc.)
  • #27 20393891
    pcichomski
    Level 16  
    vivaldi_190 wrote:
    I repeat the question to @pcichomski did you get information about your questions
    "I asked about:
    - drawing diagrams
    - servicing devices, machines, lines in the field of automation
    - comprehensive implementation (on one invoice) (delivery of components, design, fabrication, assembly, programming, etc.)


    I got the answer as below.
    PLC & HMI Programming: Sole Proprietorship, PKD 62.01.Z Classification & Favorable Lump Sum

    Generally, PLC programming is subsumed under IT.
    I talked to the person who prepared this document, asking why "33.60.20.0" cannot be used for PLC programming, since the GUS interpretations literally say that this group also applies to "technical programming of industrial controllers and robots". The guest said that it was about some reprogramming of the robot or machine (ad hoc?) and not writing a program. I felt that he didn't know what was going on at all and was rambling, but he said so and that's it.
    So I finally use:
    - writing programs - like IT - 12%
    - comprehensive design (documentation, program, etc.) - engineering design - 14%
    - services, minor program changes at the machine - as service and "technical programming" - 8.5%
  • #28 20398357
    jestam
    Automation specialist
    pcichomski wrote:

    The guest said that it was about some reprogramming of the robot or machine (ad hoc?) and not writing a program. I felt that he didn't know what was going on at all and was rambling, but he said so and that's it.

    "Technical programming" is written, which supposedly means "reprogramming", as opposed to "non-technical programming", which would mean "programming". It remains to draw the program instead of writing it. Everything is clear, as usual in the relationship between a citizen and an official.
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  • #29 20398443
    pcichomski
    Level 16  
    jestam wrote:
    pcichomski wrote:

    The guest said that it was about some reprogramming of the robot or machine (ad hoc?) and not writing a program. I felt that he didn't know what was going on at all and was rambling, but he said so and that's it.

    "Technical programming" is written, which supposedly means "reprogramming", as opposed to "non-technical programming", which would mean "programming". It remains to draw the program instead of writing it. Everything is clear, as usual in the relationship between a citizen and an official.


    That's the truth. Unfortunately, I had the impression that the guest had absolutely no idea what controller programming was, he applied a typical IT measure to it, "you write a program, transfer it on a carrier, create some code" and stuff like that. Kind of like explaining it to my wife :) . And about this "Technical Programming" from the 33rd group, this quote: "we talked with colleagues and we came to the conclusion that it was about reprogramming the machine, the robot, so that it would work differently". They concluded!!! But what will you do to them? That's what they wrote in the opinion and that's the only one I have if the US started to pull me. Such a country.
  • #30 20398540
    vivaldi_190
    Level 10  
    @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

Topic summary

The discussion revolves around the classification of PLC and HMI programming activities under the PKD 62.01.Z code for "computer programming" and the potential for using a more favorable lump sum tax rate. Participants explore the applicability of various PKD codes, including 33.20.6 for "Industrial process control system installation services," and the implications of these classifications on tax rates. The consensus suggests that PLC programming can be classified under both PKD 62.01.Z and 33.20.6, with the latter potentially allowing for an 8.5% lump sum tax rate. However, there are concerns about the interpretation of services and the need for individual tax consultations to clarify specific cases. The discussion highlights the importance of accurate classification to optimize tax benefits while navigating the complexities of Polish tax regulations.
Summary generated by the language model.
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