Since Poland’s deposit return scheme came into force (on 1 October 2025), businesses have faced new accounting and tax questions. One of the most common is whether a deposit paid on bottles or cans that can no longer be returned may be treated as a tax-deductible expense.

The good news: both the Polish Ministry of Finance and the National Revenue Information Service (KIS) have confirmed that, under certain circumstances, the answer is yes.

When is a deposit not tax-deductible?

As a general rule, paying a deposit is not a tax-deductible expense, because it is refundable. Once the packaging is returned, the business recovers the amount paid (PLN 0.50 per PET bottle or can, PLN 1 per reusable glass bottle).

As long as the deposit can be reclaimed, the expense is not considered final, and therefore cannot be deducted for tax purposes.

What happens if the packaging cannot be returned?

The situation changes when returning the packaging becomes impossible due to circumstances related to the business activity.

Examples include situations where:

• the packaging is damaged during an event,
• it is accidentally thrown away by an employee,
• it is taken by a customer or business partner,
• organisational circumstances make its return impossible.

In these cases, the business permanently loses the deposit – the payment is no longer refundable and becomes a final expense.

The Ministry of Finance’s position

In its response published on 28 April 2026 (via the Eureka platform), the Ministry of Finance stated that it cannot be assumed that an unrecovered deposit can never qualify as a tax-deductible expense.

If the expense:

• is directly related to the business activity,
• is incurred to generate, preserve or secure a source of income,
• and is properly documented,

it may be recognised as a tax-deductible expense (under Article 15(1) of the CIT Act and Article 22(1) of the PIT Act).

Confirmation by the National Revenue Information Service (KIS)

This approach was confirmed in an individual tax ruling issued on 25 May 2026 (Reference No. 0111-KDIB1-3.4010.143.2026.1.JG).

The case involved a public cultural institution organising cultural and sporting events. During these events, some bottles and cans were damaged or taken away by participants, making it impossible to return them and recover the deposits.

KIS concluded that such losses constitute a normal business risk associated with the organisation’s activities. As a result, the unrecovered deposits may be recognised as tax-deductible expenses.

What does this mean for businesses?

Each case should be assessed individually, but the positions taken by the Ministry of Finance and KIS are favourable for taxpayers. Note that the Ministry’s response does not offer the protection of a general tax ruling, so documentation is key.

Businesses should:

• properly document the circumstances preventing the return of the packaging (e.g. a loss report),
• demonstrate that the expense is connected with their business operations.

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Frequently Asked Questions (FAQ)

Is a paid deposit a tax-deductible expense? As a rule, no – while it remains refundable, it is tax-neutral. It can become an expense only when recovery is impossible.

When can an unrecovered deposit be tax-deductible? When the expense relates to your business, is incurred to generate or secure income, and is properly documented.

Does the Ministry’s position protect a business like a ruling? No. The Ministry’s response does not offer the protection of a general tax ruling, so documenting the loss is essential.