Lump-Sum Taxation for Internet Creators – Key Conclusions from the KIS Interpretation

Paweł Gorzelec
6 days ago
2 min read

The increasing popularity of subscription platforms encourages more online creators to formalize their activities by establishing a sole proprietorship. With this comes the question of the most suitable taxation method. The latest individual interpretation issued by the Director of the National Tax Information on 18 November 2025 (0115-KDST2-1.4011.463.2025.2.MR) clarifies how tax authorities assess creator income and whether it may be taxed under the lump-sum regime.

Creator as an Entrepreneur – Clear Qualification

The applicant planned to run an online profile, publishing:

original videos,
podcasts,
articles.

Subscribers could choose to financially support the creator through monthly payments. Although the platform acted as an intermediary (deducting a commission and transferring the remaining amount), the income still originated directly from the creator’s business activities.

The content was not produced on individual order but made available to all subscribers, who gained benefits such as early access, exclusive content or access to a private community.

This business model meets the criteria of entrepreneurial activity defined in the Polish Personal Income Tax Act:

✔ profit-oriented

✔ continuous and organized

✔ carried out in one’s own name

✔ involving entrepreneurial risk

At the same time, none of the exclusion criteria apply—the creator remains independent and does not perform subordinated work.

Can a Creator Choose Lump-Sum Taxation? KIS: Yes

The tax authority confirmed the right to choose the lump-sum regime if the creator:

starts the business during the tax year,
does not perform activities excluded from lump-sum taxation,
does not provide services to a former employer,
files the election statement on time.

The interpretation clearly confirms: the subscription-based model of online creator activity does not prevent the application of lump-sum taxation.

Why Monitoring Revenue Structure Matters

Creator activity evolves naturally. Additional revenue streams may include:

commercial collaborations,
sponsored content,
commissioned work,
product or digital goods sales.

Each may require a separate lump-sum rate or, in some cases, exclude the creator from the lump-sum regime entirely. Continuous monitoring is therefore crucial to keep tax compliance in order.

Record-Keeping Requirements

Although lump-sum taxation does not require tracking expenses, it does require accurate recording of revenues. In the subscription model, creators must:

correctly determine the revenue recognition moment,
reconcile revenue with platform statements,
archive all supporting documents.

Only consistent compliance ensures the protective effect of the tax interpretation.

When to Request a New Interpretation?

The protective effect applies only if the actual activity matches the description provided in the original request. When new revenue streams or business models emerge, creators should consider applying for another interpretation to ensure tax certainty.

Key Takeaways

subscription-based creator activity qualifies as non-agricultural business activity,
platform mediation does not exclude lump-sum taxation,
PKWiU classification is not required in the interpretation request,
creators must determine the correct lump-sum rate for each type of revenue.