On January 2, 2026, the Minister of Finance and Economy has issued a General Interpretation regarding the taxation of container objects under the immovable property tax regulations effective from January 1, 2025.
This document resolves doubts concerning the definition of “permanent attachment to the ground” – a key criterion for classifying objects mentioned in item 10 of list of objects other than buildings understood as a non-building structure i.e., a “container facility permanently attached to the ground”. The interpretation clarifies that for a container to be considered as such, a physical connection to the ground (e.g., anchors, bolts) is required to ensure stability against external factors.
Therefore, the Ministry confirmed that mere placement of a container on concrete blocks or paving stones does not meet the definition of “permanent attachment to the ground”.
This interpretation is significant for businesses utilizing portable container solutions, as it may impact the qualification of assets and tax liabilities. If you have any questions regarding the impact of this interpretation on your tax settlements, please contact Mikołaj Machnio (mmachnio@cmwlegal.pl) or Joanna Zinko (jzinko@cmwlegal.pl).