Bank car and caravan as cars with full VAT deduction


On April 1, the Regulation of the Minister of Finance of March 27, 2014 on motor vehicles considered to be used only for the taxpayer's business (hereinafter: the regulation) entered into force. This executive act to the Value Added Tax Act (hereinafter: the VAT Act) specifies the catalog of vehicles benefiting from full deduction

Hearse and bank car

Pursuant to Art. 86a paragraph 9 of the VAT Act, vehicles used exclusively for the taxpayer's business activity are motor vehicles that are vehicles for special purposes. Among them, you can distinguish such vehicles as:

  • electric / welding aggregate,
  • drilling vehicle,
  • excavator,
  • backhoe bulldozer,
  • charger,
  • a hoist for construction and assembly works,
  • truck crane.

It is worth remembering that under Art. 86a paragraph 16, the proper minister of public financies may determine, by regulation, other than those mentioned in para. 9 motor vehicles, considered to be used only for the taxpayer's business, requirements for these motor vehicles and documents confirming compliance with the requirements, taking into account the specificity of their construction and their use, and in the case of vehicles with more than one row of seats - also the requirement that the permissible total weight should be greater than 3 tons.

Therefore, pursuant to § 2 of the regulation, the catalog of these vehicles was extended to include the following vehicles:

  • funeral,
  • armored vehicle - only type A and B

- if they have one row of seats or their permissible total weight is greater than 3 tonnes.

The special vehicles mentioned in this executive act must meet a number of technical and sanitary requirements in order to benefit from the full deduction. These were included:

  • in § 4 sec. 1 and 2 of the Regulation of the Minister of Health of 27 December 2007 on the issue of permits and certificates for the transport of human bodies and remains (Journal of Laws No. 249, item 1866) - in the case of a funeral vehicle;
  • respectively, in Appendix No. 3 or Appendix No. 4 to the Regulation of the Minister of Internal Affairs and Administration of September 7, 2010 on the requirements for the protection of monetary values ​​stored and transported by entrepreneurs and other organizational units (Journal of Laws No. 166, item 1128, of 2012, item 1262 and of 2013, item 1652) - in the case of an armored vehicle.

The design of all the above-mentioned vehicles indisputably excludes their use for private purposes or makes the possible use for private purposes irrelevant.

It should be noted that the Minister of Finance, when expanding the catalog of special vehicles to include bank cars, only included type A and B vehicles. benefited from the deduction of VAT at all. Such a potential possibility will arise when the holder (taxpayer) decides to keep vehicle mileage records for VAT purposes and registers the car with the office, thus excluding the use of an armored vehicle for non-business purposes.

How to confirm the specification of a special vehicle?

It should be added that the documents confirming the fulfillment of technical requirements are those issued in accordance with the road traffic regulations.

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As noted in the explanatory memorandum to the regulation, in practice there may also be different factual states that were not included in the implementing act by the legislator. An example may be a vehicle specially factory-adapted to its function or a delivery vehicle (passenger car or converted into an armored vehicle).

In the explanatory memorandum to the implementing act, it can be found that: “ (...) the regulation does not explicitly indicate the documents on the basis of which compliance with the requirements specified for a given vehicle will be ascertained. In each case, the scope of documents confirming the fulfillment of specific requirements will be different. For example, you can indicate here the registration certificate (temporary permit) and additional documents specifying a given type of vehicle (certificate from the technical examination carried out confirming the fulfillment of the requirements specified for a given type of vehicle).”