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MACIEJ DĘBOWSKI
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How I obtained a tax ruling for a marketplace without an adviser

KMP-004 Case study 2 min read

I wrote the individual tax ruling application for Melly myself. What worked and what I learned along the way.

Melly connects tourists with operators who drive them in electric carts. The customer pays one amount and the platform takes a service fee from it. Simple on paper. In practice three questions appear immediately: who provides the transport service, does the platform need a fiscal cash register, and how should its own service be classified.

Why a ruling and not an adviser’s opinion

An adviser’s opinion protects the adviser. An individual tax ruling protects the taxpayer: if you act in line with it, the authority cannot later challenge the same set of facts. For a product meant to expand to more resorts, that is a foundation, not a formality.

How I built the application

  1. Facts written like a specification. I described the flow of money and responsibility step by step: who orders, who accepts the job, who performs the ride, who gets paid and when. No adjectives, only events.
  2. Service classification. I separated the platform’s service (matching the parties, PKWiU 62.09.20.0) from the transport service performed by the operator.
  3. Sector rules. I added context from road traffic law and the type approval of low-speed vehicles, because that determines what a cart ride legally is.
  4. My own position. Every question ended with a clear answer the authority could confirm or reject.

The follow-up request

The National Tax Information office asked for additional details. That is normal and is not a refusal. I replied on time, clarifying exactly what the official asked about and nothing more.

The result

On 17 September 2026 my position was confirmed as correct. The platform needs no fiscal cash register and documents its fee with an electronic payment confirmation, while the operator documents the rides.

Takeaways for founders

  • A business model and its legal qualification are one project, not two. Design them together before you write payment code.
  • Describe facts the way you describe a system: flows, roles, events.
  • A follow-up request is a question, not a verdict.

This describes my own experience and is not tax advice. Every set of facts needs its own analysis.