Poland's Director of Krajowa Informacja Skarbowa has accepted an employer's proposed gift and prepaid cards as monetary benefits for a social-fund tax exemption, while rejecting its view that tax must first be deducted from the amount loaded onto a card. The individual interpretation was issued on September 9 and published in the official EUREKA database on September 10. [S01]

The decision concerns a described future arrangement funded entirely from the employer's Company Social Benefits Fund, known as ZFŚS. Employees' eligibility and card values would depend on their living, family and financial circumstances. No employer, issuer or card network is named.

How the annual ceiling applies to balance-based cards

The PLN1,000 ceiling was already in force before this interpretation. In its June 6, 2024 response, the Finance Ministry explains that the ordinary annual limit had been PLN1,000 from 2018, temporarily rose to PLN2,000 for 2020–2023 under the COVID-era provision, and returned to PLN1,000 from 2024. The September 2026 ruling applies that existing ceiling; it does not announce a fresh reduction. [S02] [S01]

The data behind the story

Poland’s qualifying social-benefit exemption: annual ceiling

Statutory annual limits for qualifying employee social benefits. The September 2026 interpretation applies the restored PLN 1,000 ceiling to the described cards.

PLN per employee per tax year
Sources
Polish Finance Ministry, June 6, 2024 response, pages 1–2; KIS individual interpretation, September 9, 2026

Legal exemption ceilings, not card denominations, actual employee awards or a new September 2026 tax cut. Qualifying benefits aggregate across the tax year; temporary COVID-era treatment ended after 2023. The ruling’s funding and social-allocation conditions still apply.

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Poland’s qualifying social-benefit exemption: annual ceiling (PLN per employee per tax year)
CategoryAnnual qualifying-benefit ceiling
2018–20191,000 PLN per employee per tax year
2020–2023 temporary limit2,000 PLN per employee per tax year
2024 onward, including September 20261,000 PLN per employee per tax year

In the proposed arrangement, each card provides access to a defined monetary balance. Purchases reduce that balance and any remainder can fund later transactions. Gift cards would work with merchants selected by the employer, while prepaid cards would allow the employee to choose counterparties. [S01]

The authority treated both as monetary benefits under article 21(1)(67) of the personal income tax law. Its reasoning focuses on access to monetary value and successive payments, rather than the card's label. Restricting the gift card to employer-selected merchants did not change that conclusion on the submitted facts.

That distinction matters because the provision excludes vouchers, tokens and similar instruments from its definition of qualifying benefits in kind. The ruling does not remove that exclusion generally; it explains why these particular balance-based cards fall into the monetary-benefit category.

The interpretation says qualifying benefits can use an aggregate PLN1,000 annual exemption where the full social-fund financing and social-allocation conditions are met. The limit covers qualifying benefits collectively during the employee's tax year. It is not a separate allowance for every card. [S01]

Amounts above the applicable aggregate limit remain taxable employment income. The employer must include the excess in the relevant month's income calculation and calculate, collect and remit the tax advance under the payroll rules.

The authority rejected a different proposition: that compliance necessarily requires reducing the card's load by the tax amount before handing it to the employee. The distinction concerns how withholding obligations are fulfilled, not whether the excess escapes tax.

The decision gives benefit administrators a concrete example of how card operation and funding conditions can affect tax classification. Its protective effect is limited to the applicant following the interpretation on matching facts, subject to statutory exceptions. It is an individual interpretation of existing law, not a new exemption or blanket approval of every employee gift-card programme.