Purchase of a production line and the robotisation tax relief

Industrial robot

Pursuant to Article 38eb(3) of the CIT Act, an industrial robot is defined as an automatically controlled, programmable, multi-purpose, stationary or mobile machine with at least three degrees of freedom, possessing either manipulative or locomotion capabilities for industrial applications, which meets all of the following conditions:

• it exchanges data in digital form with control, diagnostic or monitoring devices for the purpose of remote control, programming, monitoring or diagnostics;
• it is connected to ICT systems that improve the taxpayer’s production processes, in particular production management, planning or product design systems;
• it is monitored using sensors, cameras or similar devices;
• it is integrated with other machines within the taxpayer’s production cycle.

The legislator introduced a detailed definition of an industrial robot, which in practice may give rise to interpretative doubts, especially for those without specialist technical knowledge.

The key practical issue is determining whether a given device possesses the characteristics required to be classified as an industrial robot under tax regulations. Another question arises as to whether these characteristics must be present in a single machine or whether they may be fulfilled collectively by a set of interconnected devices forming a production line.

For example, in the case of a bottling line purchased by a beverage manufacturer, the acquisition involves a set of closely integrated and cooperating machines. In practice, it is often difficult to identify one specific device that can be unequivocally classified as an industrial robot. This is due to two reasons. First, devices within a production line may only collectively exhibit the characteristics of an industrial robot. Second, production lines are often recognised as a single fixed asset, which makes it difficult to distinguish individual components.

Therefore, if a set of devices operating within a production line as a whole meets the criteria of an industrial robot—such as programmability, multi-functionality, connection with ICT systems and integration with other machines within the production cycle—it appears justified to treat such a set of devices as an industrial robot within the meaning of the robotisation tax relief provisions.

Position of the tax authorities

Tax authorities take the position that the acquisition of an entire production line cannot be covered by the robotisation tax relief. The Head of the National Revenue Information Service (KIS) indicates in particular that:

• the definition in Article 38eb(3) of the CIT Act refers to a machine integrated with other machines or devices within the production cycle, rather than a set of machines and devices that would collectively constitute an industrial robot (ruling of 2 June 2025, ref. 0111-KDIB1-3.4010.186.2025.1.MBD);
• a production line constitutes a set of machines and devices, which may include robots, but is not itself a robot (machine) together with functionally related and integrated peripheral equipment within the meaning of the robotisation tax relief provisions (ruling of 20 March 2024, ref. 0111-KDIB2-1.4010.599.2023.2.AR).

This approach has also been approved by some regional administrative courts (e.g. judgments of the Voivodeship Administrative Court in Lublin of 10 December 2025, ref. I SA/Lu 428/25; in Gdańsk of 4 November 2025, ref. I SA/Gd 618/25; in Wrocław of 24 October 2024, ref. I SA/Wr 423/24).

Voivodeship Administrative Court in Warsaw: a set of machines may constitute an industrial robot

In its judgment of 21 January 2026 (ref. III SA/Wa 2178/25, oral reasoning), the Voivodeship Administrative Court in Warsaw held that an industrial robot does not have to be a single machine. The legislator did not define the term “machine” nor exclude the possibility of recognising a set of cooperating devices as a robot.

The Court emphasised that, in economic reality, such solutions usually operate as components of larger, integrated technological systems. Moreover, when interpreting the provisions on the robotisation tax relief, their purpose cannot be disregarded—namely, to encourage businesses to increase their production capacity. This approach is also supported by the structure of Article 38eb of the CIT Act, which allows a range of different devices to be covered by the relief.

Consequently, if a set of machines forming a production line collectively exhibits the characteristics of an industrial robot, the relief should apply to the entire line.

Summary

In the context of applying the robotisation tax relief to production lines, the latest judgment of the Voivodeship Administrative Court in Warsaw is of particular importance. The Court acknowledged the realities of modern manufacturing, where automation is not based on individual machines but on integrated systems of devices. Such systems may constitute the basis for claiming the relief.

At the same time, this judgment currently remains the only ruling presenting such a favourable approach for taxpayers. Although the robotisation tax relief is only available until the end of this year, the issue of whether entire production lines may be covered will likely continue to be addressed in future administrative court rulings. The position of the Supreme Administrative Court will be decisive in this respect.

How we can support in relation to the robotisation tax relief

At MDDP, we assist in the application of this and other tax reliefs – from assessing eligibility, through preparation of documentation, to reporting the relief in tax returns.

The full scope of our support in relation to the robotisation tax relief is available on our website.