Indirect costs are outlays without which the business could not function, but which cannot be attributed to a single specific program or service: accounting support, internet, phone, car leasing, office rent. In IP Box they reduce income from the qualified intellectual-property right, even though they are not taken into account in the nexus indicator. If the entrepreneur also has revenue outside IP Box, part of such outlays must be assigned to each type of revenue according to the proportion set out in the PIT Act.
Where indirect costs matter and where they do not
IP Box settlement consists of two stages. First, income from the qualified right is determined: revenue from that right less the costs of earning it. Then this income is multiplied by the nexus indicator. Indirect costs take part only in the first stage.
The podatki.gov.pl service calculates income from the qualified IP as revenue reduced by costs that helped to earn it — both directly and indirectly. Article 30ca(5) of the PIT Act, by contrast, excludes from the nexus indicator costs that are not directly connected with the right — in particular interest, financial charges and real-estate outlays. The same outlay may therefore reduce the base for the 5% tax and at the same time not affect the indicator. Details on letters a–d in the formula are described in the article on direct costs in IP Box.
Which programmer outlays are usually indirect
Whether a cost is indirect is determined by its function, not by its name on the invoice. Typical examples in a one-person IT firm:
- accounting and advisory services, bank charges for keeping the account,
- internet, phone subscription, electricity in the part used in the firm,
- rent for an office or a place in a shared space, premises costs,
- leasing, fuel and insurance of a car used in the business,
- civil-liability insurance, office suite, office supplies,
- equipment and software, if they serve the whole business, not just one project.
A laptop on which only IP Box code is created can be treated as a cost directly connected with that right. When the same computer also serves for training, consultations or maintenance work without a creative element, the depreciation write-offs become a mixed cost subject to allocation.
Allocation by proportion of revenue
The PIT Act contains no separate key for IP Box, but has a general rule in Article 22(3): if it cannot be determined which part of the costs relates to particular sources, they are divided in the ratio of revenue from these sources to total revenue. The Ministry of Finance in its guidelines of 15 July 2019 indicates that outlays functionally related to revenue from qualified IP, including indirect ones, should be assigned to it. In practice, the revenue proportion is the easiest key to defend.
Step by step:
- Determine revenue from qualified rights (in line with the IP Box register) and other revenue from the business for the whole year.
- Calculate the share of IP revenue in total revenue.
- Separate out the costs that can be attributed directly: costs of IP Box projects only go in full to IP, costs of other activity only — in full outside IP.
- Multiply the remaining, common outlays by the calculated share.
- Record the calculation in the register, with the date and a description of the method adopted.
Other keys, for example work time from the work log, may better reflect reality if the business is very diverse. Departing from the revenue proportion is, however, worth justifying in writing, and for larger amounts — confirming in an individual tax interpretation.
Worked example
A programmer on flat tax (podatek liniowy) earned in 2026 PLN 240,000 of revenue from the paid transfer of rights to software being developed (covered by IP Box) and PLN 60,000 from running training sessions, which does not belong to IP Box. Total revenue is PLN 300,000, so the IP share is 80%.
| Item | Amount | IP Box part | Other part |
|---|---|---|---|
| Licences for tools used only in IP projects | PLN 6,000 | PLN 6,000 | PLN 0 |
| Room rental for training | PLN 3,000 | PLN 0 | PLN 3,000 |
| Common costs: accounting, internet, leasing, office | PLN 24,000 | PLN 19,200 | PLN 4,800 |
| Total | PLN 33,000 | PLN 25,200 | PLN 7,800 |
Income from the qualified right is PLN 240,000 − PLN 25,200 = PLN 214,800. If the entrepreneur writes the code himself and does not buy work results from related entities or ready-made rights, the nexus indicator will be 1, and the 5% tax will be calculated on that amount (before settling contributions and other deductions). Training income, i.e. PLN 60,000 − PLN 7,800, is taxed according to the existing form — here at 19%.
What happens when indirect costs are omitted
Sometimes all common outlays stay in the "other" part because it is simpler. The effects are twofold. First, the income covered by the preference is inflated, and the income from other activity is understated; with little non-IP revenue, that second part may even show an artificial loss. Second, the settlement stops matching the rule of Article 22(3), which on inspection leads to correction of both results.
The reverse mistake is assigning to IP Box costs that relate only to another activity, e.g. renting a training room. This reduces income taxed at 5% and raises income taxed higher, so it usually works against the taxpayer — but it also means an unreliable register.
When the entrepreneur has no revenue outside qualified rights, allocation is not needed: all business costs, direct and indirect, reduce IP income. This must, however, be shown by a register from which it follows that every revenue comes from a qualified right.
Documentation of the allocation key
Under Article 30cb(2) of the PIT Act, a taxpayer keeping a KPiR (tax book of revenue and expenditure) shows revenue, costs and income from each qualified right in a separate register. The allocation key for indirect costs should be part of it. It is worth keeping:
- an annual summary of IP and non-IP revenue, consistent with the book,
- a list of costs attributed directly and a list of common costs,
- a calculation of the proportion and amounts assigned to each part,
- a short description of the method, and for a key other than the revenue proportion — its justification.
The proportion is calculated for the whole year, because the relief is applied only in the annual return — during the year the advances are paid at the usual rate. The requirements for the register itself are discussed in the text on the IP Box register, and the basic conditions of the relief — in the article IP Box 2026.
How Good Balance can help
We prepare a separate IP Box register together with the cost-allocation key, we keep the tax book of revenue and expenditure so that revenue from rights and from the rest of the activity is separated from day one, and we help prepare an application for an individual tax interpretation when the entrepreneur wants to apply a key other than the revenue proportion.