A machine bought in December: one-off depreciation in 2026 or 2027 — 213 000 zł, 219 000 zł and 100 000 zł

The December Question

Every year, somewhere around the 10th of December, a client calls with the same idea: "I'll buy the machine now, so it goes into this year's costs." Sometimes it's a CNC lathe, sometimes a van, sometimes six laptops and a server.

The honest answer is "maybe", and it depends on three things the client rarely mentions on the phone. When the asset will actually arrive and work. Whether the client is a small taxpayer in that year. And whether this year is the right year to take the deduction at all.

Here are the numbers for the 2026/2027 boundary and the checks I'd run in November, while there's still time to change the plan.

Two Routes, Three Numbers

There are two separate one-off depreciation routes in the PIT and CIT Acts. People mix them up all the time.

	De minimis route (art. 22k(7) PIT / 16k(7) CIT)	100 000 zł route (art. 22k(14) PIT / 16k(14) CIT)
Who	small taxpayers and taxpayers starting a business	any taxpayer
What	fixed assets in KŚT groups 3–8, except passenger cars	brand-new fixed assets in KŚT groups 3–6 and 8
Annual limit	50 000 euro: 213 000 zł in 2026, 219 000 zł in 2027	100 000 zł
Extra condition	the aid counts towards the client's de minimis ceiling	one asset ≥ 10 000 zł, or two totalling ≥ 10 000 zł with each above 3 500 zł

The euro limit is converted at the average NBP rate from the first working day of October of the previous year and rounded to 1 000 zł. For 2026 that's 4.2586 zł, for 2027 it's 4.3770 zł, the same rate behind the 2027 limits I wrote about last week.

Two more rules matter in practice. First, write-offs on assets of up to 10 000 zł that are expensed directly don't count towards the euro limit (art. 22k(9)). The six laptops don't eat into the machine's room. Second, for one asset you use one route or the other (art. 22k(20)). Different assets can use different routes in the same year, so a small taxpayer can put a used van through the de minimis route and a brand-new press through the 100 000 zł route.

Passenger cars are out of both. Vans and trucks from group 7 can go through de minimis but not through the 100 000 zł route. For cars, the limits from the 100 000 zł car-limit post apply anyway.

The Date That Decides: Entry Into the Register

The write-off belongs to the tax year in which the asset is entered into the fixed asset register. An asset can be entered once it's complete and fit for use. Not when it's ordered, not when it's paid for, and not on the invoice date.

That's where December plans fall apart. A client orders a machine on 5 December, the supplier invoices it on 20 December through KSeF, and the machine arrives on 12 January and is installed on the 15th. For tax purposes it's a 2027 asset. It doesn't matter that the invoice sits in the December purchase register. The post on year-end purchase invoices in KSeF covers that difference between invoice date and economic date for ordinary costs. For fixed assets it's sharper, because the whole write-off moves by a year.

So the first question to the client isn't "how much?". It's "when will it be standing in the workshop, connected and working?" Ask for the acceptance protocol (protokół przyjęcia) or at least a delivery note dated 2026. Without it, the 2026 entry is a risk in an audit.

Why December and January Aren't Interchangeable

For a small taxpayer, moving the purchase across 1 January changes which limit and which status apply.

• Entered in December 2026: uses the 2026 limit of 213 000 zł and requires small-taxpayer status in 2026, which means 2025 sales including VAT of no more than 8 517 000 zł.
• Entered in January 2027: uses the 2027 limit of 219 000 zł and requires status in 2027, which means 2026 sales including VAT of no more than 8 754 000 zł.

The interesting clients are the ones near those lines. A client with gross sales of 9.1 million zł in 2026 is a small taxpayer in 2026 (assuming its 2025 sales were under 8 517 000 zł) but not in 2027. For that client, December is the last chance for the de minimis route. If the machine slips into January, only the 100 000 zł route is left, and only if the machine is brand-new.

The reverse also happens. A client that already used most of its 2026 limit, say 190 000 zł on a machine in June, has 23 000 zł left this year and 219 000 zł from January. A 150 000 zł purchase is better entered in January.

A Worked Example

A sole trader on flat-rate PIT (19%), small taxpayer in both years, buys a used CNC machine for 180 000 zł net. VAT is deductible, so the initial value is 180 000 zł.

• Standard depreciation, entered in December 2026. Depreciation starts the month after entry, so the 2026 write-off is zero. With a 10% straight-line rate, it's 18 000 zł a year from 2027.
• De minimis, entered in December 2026. The full 180 000 zł is a 2026 cost, within the 213 000 zł limit. At 19% that's 34 200 zł less tax for 2026. On the flat rate it also lowers the base for the health contribution, which is calculated from income.
• De minimis, entered in January 2027. The same 180 000 zł lands in 2027, within the 219 000 zł limit, and the tax saving moves by a year.

The decision isn't "December good, January bad". It depends on income. If this client expects 400 000 zł of income in 2026 and less in 2027, December is right. If 2026 income is 60 000 zł, a 180 000 zł write-off creates a 120 000 zł loss. That loss can only be used later under the loss rules. Spreading the deduction, or entering the asset in January, would be worth more. On the progressive scale this bites even harder, because a write-off that lands at 12% instead of 32% throws away most of its value.

And for clients where the question disappears, say so plainly. On ryczałt there is no depreciation cost at all. On Estonian CIT tax is paid on distribution, so the timing of tax depreciation hardly matters. The Estonian CIT post covers who that applies to from 2027.

De Minimis: The Part Nobody Tallies

The de minimis route is state aid. Under Regulation (EU) 2023/2831 the ceiling is 300 000 euro per undertaking over a rolling three years, and it counts all de minimis aid the client has received: ZUS relief, PFRON, local grants, earlier one-off depreciation. Related companies count together.

Two things go wrong here. First, the aid value isn't the write-off. It's the gross grant equivalent of paying the tax later, which is much smaller, and it's calculated with the formula in the aid regulations. Offices that put 180 000 zł into the tally overstate it. Offices that put nothing understate it, and the client finds out when a grant application gets rejected. Second, nobody owns the tally. The client got a grant through a different advisor, the ZUS relief was two years ago, and the office only knows about the depreciation. The UOKiK SUDOP search shows aid registered for the client and is a reasonable first check.

On full books there's one more consequence. The one-off write-off is a tax figure. In the balance sheet the machine is still depreciated over its useful life, which creates a temporary difference. For clients who keep a deferred-tax register, it goes into the year-end deferred tax list. For those using the art. 37(10) exemption, you still want to know why tax and book depreciation will diverge for the next ten years. The asset also shows up in the JPK_ST_KR fields for tax and book depreciation.

The November List

What I'd want for every client before 1 December:

1. Planned purchases. Which clients intend to buy equipment before year end, and the expected delivery and installation dates. One email in mid-November gets most of the answers.
2. Status in 2026 and 2027. 2025 and 2026 gross sales against 8 517 000 zł and 8 754 000 zł. Clients who lose the status in 2027 go to the top of the list.
3. Limit already used in 2026. One-off write-offs entered this year, per route.
4. Expected 2026 income. A rough figure is enough to rule out the loss-year trap.
5. De minimis tally. Aid in the last three years, from the client and from SUDOP.
6. December invoices without a 2026 entry. In the first week of January: purchase invoices for fixed assets dated December where the asset was entered in January, or not at all.

Where an Agent Fits

Most of that list comes from data the office already has. An agent reads purchase invoices from KSeF for November and December and flags likely fixed assets: net value above 3 500 zł, descriptions such as machines, equipment or vehicles, and supplier types. It filters out passenger cars by description and CN code. For each client it calculates the status checks from the sales register, sums the one-off write-offs already in the fixed asset register this year, and lists December invoices with no matching register entry.

The output is one line per client: candidate asset, invoice date, register entry date if any, which route is available, how much limit is left, and what's missing (for example, no acceptance protocol). It doesn't enter assets, choose a method or book anything. The accountant makes the decision, ideally with the client's expected income on the table.

One Question for This Week

Which of your clients asked about "buying something before the end of the year" last December? Most offices can name five without looking. Send them the mid-November email now, while delivery dates can still be moved.

If you want to see what that list looks like for your portfolio, send me an anonymised November–December purchase register from last year and I'll show you which invoices the agent would flag.