In 2026 a data analyst on a sole proprietorship may pay ryczałt (lump-sum tax on recorded revenue) at 8.5%, 12% or 15% — and each of those rates may be correct. What matters is not the job title but whether the client is buying a software-related service, data processing, market research or advisory for management. The same dividing line affects the PKD code and whether a turnover-based VAT exemption up to PLN 240,000 is available. Below is a simple method for assigning your own services to the correct categories.
Step 1: split services into four baskets
An analyst's work is rarely uniform. In one month it may include building a data pipeline, preparing a management dashboard, analysing a customer survey and giving recommendations to the board. It is worth assigning each item from the contract to one of the baskets:
| Basket | Sample activities | PKWiU group | Ryczałt |
|---|---|---|---|
| IT services | designing data warehouses, data transformation code, advice on choice of tools and systems | 62.01, 62.02, 62.03 | 12% |
| Data processing | full processing of the client's data, recurring reports generated from their data | ex 63.11.1 | 15% |
| Market research and advertising analytics | surveys, analysis of campaign effectiveness | section 73 | 15% |
| Management advisory | strategic recommendations, cost and process analysis for the management | ex section 70 | 15% |
Services that fit none of these groups (nor other groups with a higher rate) are taxed at 8.5% as other service activity. Data analytics has, however, so many points of contact with the groups above that the 8.5% rate is best confirmed with an individual tax interpretation.
Step 2: ryczałt — what the Act says
The Lump-Sum Income Tax Act assigns the 12% rate to, among others, services related to software, advice on hardware and software and management of IT networks and systems. The 15% rate covers data processing (PKWiU ex 63.11.1), advertising services and market research (section 73) and management-related advisory (ex section 70). The rates refer to the PKWiU 2015 classification, not to the PKD codes entered in CEIDG.
If the activity combines several baskets, the revenue records must allow amounts to be assigned to rates — the easiest way is for invoices or their attachments to split the fee by type of service. When the records do not allow this, revenue is taxed at 8.5%, while items subject to a higher rate are still taxed at the higher rate.
Example
An analyst invoices PLN 24,000 a month in 2026: PLN 16,000 for development of models and code in the client's data warehouse, PLN 5,000 for recurring reports on sales data and PLN 3,000 for quarterly recommendations for the board. With a proper split, ryczałt amounts to: 16,000 × 12% + 5,000 × 15% + 3,000 × 15% = PLN 3,120 a month (before deducting part of the health contribution). If the whole amount were taxed at 15%, the tax would be PLN 480 higher per month. More on the 12% rate in IT is in the article ryczałt in IT: 12% and 8.5%.
Step 3: PKD 2025 code
Under PKD 2025 an analyst can choose several subclasses, depending on the main part of their work:
- 62.20.B — advice on hardware, software and systems, system planning and design, auditing of systems data processing services;
- 63.10.D — among others, full processing of data supplied by clients and generation of specialist reports from that data;
- 62.10.B — when programming dominates (e.g. custom analytics tools);
- 73.20.Z — market and opinion research, including qualitative and quantitative data gathering;
- 70.20.Z — advisory to management on organisation, costs and planning.
The primary code is selected based on the main source of revenue, with the rest listed as additional. General guidance is in the guide how to choose a PKD code.
Step 4: VAT and the PLN 240,000 threshold
The turnover-based VAT exemption applies up to PLN 240,000 of sales in 2026, but it does not cover entrepreneurs providing advisory services. For an analyst this is an important distinction:
- data processing, report building or programming are not advisory — with lower turnover the exemption can be kept;
- services described in the contract as advisory (business, IT, management) rule out the exemption from the first złoty.
Often the wording alone decides — "analytical consultations" on an invoice may be assessed as advisory, even if in practice it means preparing reports. For clients in other EU countries, VAT-UE registration must be done before the first invoice, and the service is invoiced without Polish VAT.
Step 5: when an interpretation pays off
The difference between 8.5% and 15% on annual revenue of PLN 200,000 is PLN 13,000 of tax, and between 12% and 15% — PLN 6,000. At such amounts an application for an individual tax interpretation (fee of PLN 40 per factual situation) usually pays for itself. A good application:
- describes activities concretely, without generalities such as "analytical support";
- specifies the tools, the work product and who takes decisions based on it;
- separates activities that may fall under different PKWiU groups;
- matches real contracts and invoices — the interpretation only protects the described situation.
It is also worth remembering the health contribution: under ryczałt, with revenue between PLN 60,000 and PLN 300,000 it amounts in 2026 to PLN 830.58 per month, regardless of the tax rate.
Other matters worth attention
- Rights to the code. If the analyst creates software (e.g. libraries, data-processing tools) and transfers rights to it, under the flat tax or scale it is worth checking the IP Box relief conditions — under ryczałt it is not available.
- Personal data. Working with the client's data usually requires a personal data processing agreement — a RODO (GDPR) obligation independent of taxes.
- One client, employment-like rhythm. A fixed monthly amount, work in the client's team and tools over many years — these features can bring the contract close to employment during an audit.
How Good Balance can help
We help analysts split services into PKWiU categories, choose PKD codes and the form of taxation, and in borderline cases prepare an application for an interpretation. The scope of support for sole proprietorships is described on the page JDG registration and running.