# Client gifts in Poland: VAT limits and corporate tax
Source: https://norman.finance/pl/en/blog/client-gifts-poland-vat-cit
Author: Norman
Published: 2026-11-13
Updated: 2026-11-13

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**Client gifts require two separate Polish tax assessments: VAT on the free transfer and deductibility for corporate income tax, or CIT.** VAT provides a PLN 20 unit-value rule without recipient identity records and a PLN 100 excluding VAT limit per person per tax year with those records. These are not automatic CIT deduction allowances. A logo, Christmas occasion or company invoice does not settle every part of the treatment.

The rules were checked on 13 November 2026. This guide covers physical gifts to business partners in Poland from a company paying ordinary CIT. Employee gifts, vouchers, competitions and cross-border transfers need separate analysis.

## What should you decide before ordering gifts?

Record who will receive the gifts and why the company is providing them. Distinguish a broad promotional campaign, advertising items distributed at an event and an expensive personal gift for a selected partner. Similar purchase invoices can support very different business activities.

Establish the unit value, quantity, intended recipients and delivery records. Check whether the same recipient has already received other gifts in the current tax year. The campaign’s total budget cannot replace a check of the value attributable to each person.

Do not buy on the assumption that accounting can simply deduct everything afterwards. Get the proposed treatment assessed first, especially for expensive packages, alcohol or highly personal items. Also check whether the recipient’s own company policy permits accepting the gift.

## When can a free gift create output VAT?

[Article 7(2) of the Polish VAT Act](https://api.sejm.gov.pl/eli/acts/DU/2026/1263/text/U/D20261263Lj.pdf) covers specified free transfers of business goods where the taxpayer had a full or partial right to deduct input VAT on their purchase, import, manufacture or component parts. The relevant point is the right to deduct, not merely whether the company actually claimed it.

Article 7(3) provides an exception for, among other things, small-value gifts transferred for business purposes. The conditions in paragraph 4 must be met. Calling a purchase “marketing” does not replace checking its value and recipients.

Input VAT on the purchase is a separate issue. It follows Article 86, including the connection with taxable activities, and the Act’s other restrictions. Having no output VAT on a qualifying small gift does not independently establish a deduction for every purchase invoice.

## How does the PLN 20 rule work without recipient records?

Where a transfer is not included in records identifying the recipient, Article 7(4)(2) refers to the unit purchase price excluding VAT. If there is no purchase price, the unit production cost is used. The value is determined at the time of transfer and must not exceed PLN 20.

This is a unit-value test, not a limit on the whole invoice for a batch of promotional items. Forty identical notebooks at PLN 15 net each cost PLN 600 net in total, but PLN 15 per item is the starting point for this rule. The example assumes genuine separate gifts for business purposes, not an artificial division of one product.

Not needing recipient identity records for this rule does not mean keeping no evidence. Retain the purchase invoice, quantities bought and distributed, campaign description and transfer dates. These explain both the business purpose and how the unit value was established.

## How does the PLN 100 limit work with records?

Article 7(4)(1) covers goods given to one person with a total value no greater than PLN 100 excluding VAT during the tax year, provided records establish that person’s identity. The allowance does not restart with every invoice, campaign or holiday.

For example, one gift worth PLN 80 net to an identified recipient may fit this rule if there were no earlier gifts and the other conditions are met. A gift worth PLN 120 net exceeds the PLN 100 limit and also fails the PLN 20 unit test. That does not automatically prohibit the purchase; it requires assessment of output VAT on the transfer.

| Value of one example gift | What to check for the VAT exception |
|---|---|
| PLN 15 net | Unit purchase price or production cost and business purpose |
| PLN 80 net | Recipient identity, records and total gifts during the tax year |
| PLN 120 net | Failure of both thresholds in this example and potential output VAT |

Check the cumulative amount before handing over another gift. If the threshold is exceeded, do not assume VAT applies only to the amount above PLN 100. The legal assessment concerns the goods transferred and the statutory conditions, rather than a simple tax on the excess campaign budget.

## What belongs in a gift register?

A useful register connects the recipient, item and purchase record. Include the transfer date, details establishing the person’s identity, gift description, quantity, value excluding VAT, cumulative value for that recipient during the tax year and purchase invoice reference.

Also record the business purpose and the person responsible for distribution. Link shipped gifts to delivery evidence where available. Buying stock for a future campaign is not the same event as transferring the goods to recipients.

Collect the information needed for identification and accounting. This does not require copying a client’s private identity documents or personal correspondence. If the gift goes to an individual working for a business partner, establish whom the register identifies. A generic entry such as “customer company” may not explain who actually received the item.

## Can a client gift be deducted for CIT?

[Article 15(1) of the Polish CIT Act](https://api.sejm.gov.pl/eli/acts/DU/2026/554/text/U/D20260554Lj.pdf) requires expenditure to relate to earning revenue or maintaining or protecting its source. Article 16(1)(28) excludes representation expenses. The purpose and circumstances of the particular activity therefore matter.

A logo can support a promotional explanation but does not automatically make a purchase deductible. A low price does not by itself turn every personal gift into advertising either. Document the intended audience, distribution method and connection with the company’s offering. Do not invent a marketing explanation that differs from the actual purpose.

The PLN 20 and PLN 100 amounts come from VAT legislation. Do not treat them as the boundary between deductible and non-deductible CIT expenditure. The two assessments can reach different outcomes: qualifying as a small gift for VAT does not establish a CIT deduction, and a business explanation for CIT does not remove the need to examine output VAT.

For an unusual or material purchase, ask your accountant to document the reasoning before the order is approved. That gives the company a chance to change the campaign rather than trying to justify a completed purchase solely from its invoice description.

## How should you plan Christmas gifts and gift sets?

A Christmas occasion does not create an extra tax allowance. Review earlier gifts in the same tax year before the December campaign. Clarify whether the budget means net price, gross price or the full cost including packaging and delivery.

For baskets and sets, do not assume every component can always be treated as a separate gift below PLN 20. Establish what is actually being transferred and how the complete package is valued. Avoid artificially splitting a single set just to meet the threshold. Assess unusual packages before ordering, while their contents and budget can still be changed.

If the company is also buying employee gifts, keep that part of the accounting separate. Recipient status matters. A guide about business partner gifts does not determine employer obligations or any income arising for the person receiving a benefit.

## How do you close the campaign in accounting?

Connect the order, purchase invoice, distribution records and VAT and CIT decisions. Reconcile remaining stock, returns and differences between planned and actual recipients. Payment for the goods does not prove who received them or when the transfer happened.

If the purchase invoice arrived through [KSeF](/pl/en/blog/ksef-for-a-sp-z-o-o), its presence in the system does not replace evidence of purpose and distribution. The same distinction between a purchase invoice and the reason for the expense also matters for a [company mobile phone](/pl/en/blog/company-mobile-phone-poland).

Include the campaign in your [company operating budget](/pl/en/blog/how-much-does-a-sp-z-o-o-cost-per-month). Explore [accounting for a Polish limited company with Norman](/pl/en/limited-company-accounting) for the wider workflow. Prepare recipient, purpose and value information before committing to the purchase, so the tax assessment can reflect the actual plan.