Buying goods on pallets is common practice in wholesale and retail trade, especially for large orders. How you record the value of pallets in the KPiR (tax revenue and expense ledger) depends on their nature – whether they are returnable or non-returnable. Each type of pallet calls for a different accounting approach and the application of the relevant provisions of the regulation on keeping the KPiR. Pallet movements often go hand in hand with recording a WZ goods issue note in the KPiR.
Recording pallets correctly matters for settling business costs properly. Incorrect entries can lead to errors in your tax settlement and potential problems during a tax inspection. That is why every business owner who keeps a KPiR should know the rules for booking pallets.
The regulation on keeping the tax revenue and expense ledger does not refer directly to booking pallets. However, the definitions of materials and waste in the regulation make it possible to classify pallets correctly according to their nature. The key question is whether the pallet is returned to the supplier or stays permanently with the buyer of the goods
Returnable pallets – classified as materials in the KPiR
Returnable pallets are a special category of packaging that is returned to the supplier after the goods have been delivered. Under the definition of materials in § 2 point 1(b) of the regulation on keeping the KPiR (since 1 January 2026 a new regulation of 6 September 2025 applies, Journal of Laws (Dz.U.) item 1299), basic materials are materials that become the main substance of the finished product in the production process or when providing services. Basic materials also include reusable shipping packaging, such as transporters or pallets, if this packaging is not a fixed asset.
This definition clearly indicates that a returnable pallet should be classified as a basic material. This means its value should be entered in the tax revenue and expense ledger in column 12 (until the end of 2025 this was column 10), which covers purchases of goods for resale and materials at purchase prices. This approach is logical, because a returnable pallet is temporary and stops being part of the business owner's assets once it is returned to the supplier.
Returnable pallets qualify as basic materials under the definition in the regulation on keeping the KPiR. Their value should be recorded in column 12 of the ledger as a purchase of goods for resale and materials. After the pallet is returned to the supplier, the original entry is corrected by means of a corrective invoice
Recording returnable pallets usually takes two steps. First, together with the delivery of goods, the business owner receives an invoice documenting both the value of the goods and the value of the pallet. At this point the whole invoice value should be entered in column 12 of the KPiR. Then, after the pallet is returned, the supplier issues a corrective invoice that reduces the originally recorded value by the amount corresponding to the value of the returned pallet.
Under § 9 section 1 of the regulation, if a basic material was delivered to the business before the invoice was received, you must prepare a detailed description of the material received, stating the supplier's details, the quantity, type, unit price and value of the material, and then make an entry in the ledger on the basis of that description. The description is confirmed with the date and signature of the person who accepted the delivery.
Documenting the return of pallets and the correction in the KPiR
Returning returnable pallets to the supplier must be properly documented and correctly reflected in the KPiR. Most often, the delivery of goods on a pallet is documented with the original invoice, and after the pallet is returned the supplier issues a corrective invoice. This procedure complies with the rules and allows business costs to be settled correctly.
It is important to understand that returning packaging after the sale of goods and issuing a corrective invoice should not be treated as a separate business event, but as a correction of a legal transaction that took place earlier. For this reason, a corrective invoice issued for returned packaging should refer to the original invoice on which the packaging was included.
Returning returnable pallets is not a separate business event, but a correction of the original purchase transaction. The corrective invoice issued by the supplier after the pallet is returned must refer to the original invoice and contain all the elements needed to identify the corrected transaction
Under Article 22 section 7c of the PIT Act (personal income tax), if a correction of a tax-deductible cost is not caused by an arithmetical error or another obvious mistake, it is made by reducing or increasing the tax-deductible costs incurred in the settlement period in which the corrective invoice or another document confirming the reasons for the correction was received.
This means that the date on which the corrective invoice was issued does not matter, nor does the fact that the correction relates to costs of a previous period. The date of receipt of the relevant document decides when costs are corrected. Taxpayers correct tax-deductible costs on an ongoing basis, i.e. in the month in which they receive the corrective invoice or another document confirming the reasons for the correction.
Procedure for recording returnable pallets – step by step
Recording returnable pallets correctly in the tax revenue and expense ledger requires a set procedure that keeps you compliant with tax law. The detailed process is as follows:
- Accepting the goods together with the returnable pallet – on delivery, check that the quantity and type of goods and pallets match the delivery document
- Recording the original invoice – enter the whole invoice value, including the value of the pallet, in column 12 of the KPiR in the month the invoice is received
- Storing the pallet – a returnable pallet should be properly marked and stored in a way that prevents damage
- Returning the pallet to the supplier – once the pallet has been emptied, return it to the supplier in line with the terms of the contract
- Receiving the corrective invoice – the supplier issues a corrective invoice reducing the original value by the amount of the pallet
- Recording the correction – enter the corrective invoice in column 12 of the KPiR in the month it is received, with a minus sign or in red
- Archiving the documents – keep all documents relating to the returnable pallet in line with the regulations
The cost correction relating to the return of a pallet is made in the month the corrective invoice is received, regardless of the month in which the goods were originally purchased. This follows from the rules set out in the PIT Act
When recording returnable pallets, also remember that they must be included in the stocktaking (spis z natury). Under § 20 section 1 of the regulation on keeping the KPiR, taxpayers must prepare a stocktaking of goods for resale and basic and auxiliary materials and enter it in the ledger as at 1 January and at the end of each tax year. We can handle the stocktaking and day-to-day KPiR entries for you — this is what our accounting firm in Warsaw does.
Non-returnable pallets – classified as waste
Non-returnable pallets are a completely different category of packaging from returnable pallets. When a pallet is non-returnable and will not be used in any way for the needs of the business afterwards, it should be classified as waste. This classification follows from the definition of waste in the regulation on keeping the tax revenue and expense ledger.
Under § 2 point 1(g) of the regulation on keeping the tax revenue and expense ledger, waste means materials that, as a result of technological processes or as a result of destruction or damage, have completely lost their original usefulness. A non-returnable pallet that cannot be used in further business activity meets the definition of waste within the meaning of the accounting rules. Quite different recording issues, relating to a company's equity, are covered in booking share premium (agio) in a limited company.
Non-returnable pallets qualify as waste under the definition in the regulation on keeping the KPiR. These are materials that have completely lost their original usefulness and cannot be used in the business owner's further activity
Classifying a non-returnable pallet as waste has important consequences for how it is recorded in the tax revenue and expense ledger. Unlike returnable pallets, which are treated as basic materials, non-returnable pallets are not recorded as a separate item in column 12 of the KPiR. Instead, their value should increase the acquisition price of the goods, which means the value of the pallets is recorded in column 13 of the KPiR (until the end of 2025 this was column 11) as incidental purchase costs.
This approach makes economic sense, because a non-returnable pallet is an integral part of the cost of acquiring the goods. It cannot be separated from the goods and used in another way, so its value should be treated as part of the acquisition cost of the goods rather than as a separate material.
Recording non-returnable pallets in column 13 of the KPiR
Non-returnable pallets, being waste within the meaning of the accounting rules, are recorded differently from returnable pallets. Their value is not entered in column 12 of the KPiR as materials, but in column 13 as incidental purchase costs. This is because a non-returnable pallet is an integral part of the cost of acquiring the goods and cannot be separated from it.
Under § 10 of the regulation on keeping the tax revenue and expense ledger, expenses on the purchase of basic materials and goods for resale, as well as other expenses, are entered in the ledger in line with the rules for deducting tax-deductible costs set out in the income tax act. Since 2026 the regulation no longer contains the former requirement to enter a purchase immediately after receiving the goods, or to record other expenses once a day.
The value of non-returnable pallets should be recorded in column 13 of the KPiR as incidental purchase costs, not in column 12 as materials. A non-returnable pallet increases the acquisition price of the goods and is an integral part of their purchase cost
In practice, this means that when a business owner receives an invoice documenting the purchase of goods on a non-returnable pallet, the value of the goods should be entered in column 12 of the KPiR and the value of the pallet in column 13 of the KPiR. If the value of the pallet is not shown separately on the invoice but is included in the price of the goods, the whole invoice value should be entered in column 12 of the KPiR. If, however, the value of the pallet is shown separately on the invoice, it should be moved to column 13 as an incidental purchase cost.
This approach reflects the actual costs of acquiring the goods and keeps you compliant with the regulation on keeping the KPiR. At the same time, it allows proper control of business costs and their analysis by category.
Stocktaking for returnable and non-returnable pallets
Both returnable and non-returnable pallets must be included in the stocktaking. Under § 20 section 1 of the regulation on keeping the KPiR, taxpayers must prepare a stocktaking of goods for resale, basic and auxiliary materials, semi-finished products, work in progress, finished products, defective products and waste, and enter it in the ledger as at 1 January and at the end of each tax year.
The purpose of the stocktaking is to establish the actual level of stock in the business and compare it with the level shown in the records. Returnable pallets, which are classified as basic materials, should be included in the stocktaking in the relevant group of materials. Non-returnable pallets, being waste, are also included in the stocktaking in the waste group. Stocktaking is one of the steps in year-end closing in the KPiR.
All pallets present in the business on the day of the stocktaking must be included in it. Returnable pallets are recorded as basic materials and non-returnable pallets as waste. The stocktaking is prepared as at 1 January and at the end of the tax year
Pallets are valued differently in the stocktaking depending on their nature. Under § 22 section 1 of the regulation, the taxpayer must value materials and goods for resale covered by the stocktaking at purchase or acquisition prices, or at market prices on the day of the stocktaking if these are lower than the purchase or acquisition prices. Usable waste that has lost its original usefulness in the course of business is valued at an estimated amount that takes into account its suitability for further use.
In practice, this means that returnable pallets should be valued at purchase prices, or at market prices if these are lower. Non-returnable pallets, as waste, are valued at an estimated amount reflecting their suitability for further use, which in most cases will be minimal or zero.
Differences in how returnable and non-returnable pallets are recorded
The basic difference between returnable and non-returnable pallets lies in their purpose and how they are used. Returnable pallets are treated as reusable packaging that is returned to the supplier after the goods are delivered. Non-returnable pallets stay permanently with the buyer of the goods and are not returned to the supplier.
This fundamental difference has important consequences for how pallets are recorded in the tax revenue and expense ledger. Returnable pallets are classified as basic materials and recorded in column 12 of the KPiR, with a later correction after they are returned to the supplier. Non-returnable pallets are treated as waste and their value increases the acquisition price of the goods, which means they are recorded in column 13 of the KPiR as incidental purchase costs.
| Aspect | Returnable pallets | Non-returnable pallets |
|---|---|---|
| Accounting classification | Basic materials | Waste |
| KPiR column | Column 12 | Column 13 |
| Documentation | Original invoice + corrective invoice | Original invoice only |
| Stocktaking | As basic materials | As waste |
| Valuation in the stocktaking | Purchase or market price | Estimated value |
| Corrections | Required after return | Not required |
The differences also concern how pallet transactions are documented:
- Returnable pallets: documented with the original invoice and a corrective invoice after the return
- Non-returnable pallets: documented only with the original invoice, with no later corrections
- Returnable pallets: require additional records of the return and of the receipt of the corrective invoice
- Non-returnable pallets: require no additional records after the goods have been used
The key difference between returnable and non-returnable pallets lies in their accounting classification. Returnable pallets are basic materials recorded in column 12 of the KPiR, while non-returnable pallets are waste that increases the acquisition price of the goods in column 13 of the KPiR
Practical aspects of recording pallets
In everyday business, owners often face various situations involving pallets that can raise doubts about the correct way to record them. One of the most common is receiving goods on a pallet before receiving the invoice. In that case, under § 9 section 1 of the regulation, you must prepare a detailed description of the basic material, auxiliary material or goods for resale received.
The description should contain the first name, surname (business name) and address of the supplier, the quantity and type, and the unit price and value of the basic material, auxiliary material or goods for resale. The entry in the ledger is made on the basis of this description. The description is confirmed with the date and signature of the person who accepted the delivery, kept as proof of purchase and attached to the paper invoice sent later; for an invoice issued in KSeF (National e-Invoicing System), the description is supplemented with its KSeF number. Any difference compared with the value shown on the invoice is entered in the ledger on the day the invoice is received.
A transport company received a delivery of spare parts on returnable pallets worth PLN 15,000, including pallets worth PLN 500. The invoice arrived a week later. The company prepared a description of the materials and pallets received and then made an entry in the KPiR. When the invoice arrived there were no differences in valuation, so no additional corrections were made. After the pallets were returned, the company received a corrective invoice for PLN 500.
Another practical issue is determining when a returnable pallet should be returned. The return should take place within the period set out in the contract with the supplier or in line with trade practice. A late return may result in the supplier charging additional fees or in the loss of the right to return the pallet. That is why business owners should keep records of returnable pallets and monitor their return deadlines.
Checking and archiving pallet documents
Keeping proper pallet records requires not only correct booking, but also appropriate checks and archiving of documents. All documents relating to pallets, both returnable and non-returnable, must be kept for the period set out in the Tax Ordinance Act (Ordynacja podatkowa).
Documents relating to returnable pallets include:
- The original invoice documenting the purchase of goods together with the pallet
- A document confirming the return of the pallet to the supplier
- The corrective invoice issued after the pallet is returned
- Any documents concerning damage to or loss of the pallet
Documents relating to non-returnable pallets include:
- The invoice documenting the purchase of goods together with the non-returnable pallet
- Documents confirming the use or disposal of the pallet
- Any documents concerning the sale of the pallet as waste
All documents relating to pallets must be kept until the limitation period for the tax liability expires (Article 86 § 1 of the Tax Ordinance Act), which as a rule means 5 years from the end of the calendar year in which the tax payment deadline passed (Article 70 § 1). This applies to original and corrective documents as well as all supporting documents confirming pallet transactions
Checks of pallet records should include regularly comparing the actual stock with the records, monitoring return deadlines for returnable pallets and verifying that pallet transactions have been booked correctly. Pay particular attention to classifying pallets correctly as returnable or non-returnable, because an incorrect classification can lead to costs being recorded incorrectly in the KPiR.
