The 2025 presidential election showed that defending cash is an crucial area of public debate. The cash defence thread appeared not only in candidates' programs, but besides in the alleged Toruń Declaration, signed by the current president-elect – "I will not sign any law limiting cash turnover and I will stand watch over Polish gold". In contrast to social support for the defence of cash, it is worth considering a solution to reduce the imbalance between cash and non-cash turnover.
Many countries, in peculiar Western European countries, have developed a number of concepts of taxation, whether financial entities or transactions in the financial market. The most celebrated concept was the alleged Tobin tax, the aim of which was to stabilise financially and to counter the negative effects of speculation. At the same time, taxes on financial institutions be in respective countries. For example, a taxation on certain financial institutions (including home banks, branches of abroad banks and credit institutions, cooperative savings and credit banks, national insurance companies, debt institutions) should be mentioned here.
Electronic payment handling tax: yes or no?
The area presently undeveloped and omitted in the "bank tax" structure is the taxation burden on electronic payment institutions.
Entities, specified as card organizations, banks, clearing agents, operate crucial resources through their function in economical trade. They practically gain on all transaction they carry out through them, which yet consists of immense profits.
Of course, these entities are already subject to existing general taxes, specified as income tax, but in rule they function under the VAT exemption. However, the ease of avoiding it results in a advanced payment capacity, i.e. having the means to pay the taxation and the economical situation of which would not importantly deteriorate due to the tax. Thanks to the specificity of card transactions, a taxation on specified transactions would be small burdensome, even unnoticeable to citizens, as well as easy to collect, and would be taxed by entities capable of paying it.
If fresh trends in the method regulation of taxation and the fight against its avoidance are followed, the thought of additional burden on non-cash payment institutions may seem initially controversial and absurd. However, these are only appearances, as in a deeper analysis of both the sealing of the taxation strategy itself, the phenomenon of the freedom of the individual and the function of the issuer of money in the strategy of public power, this thought gains justification.
Cash-free turnover versus cash. Which one's more expensive?
However, it should be disputed first that cash trading is much more costly to operate than cash-free trading.
Such a thesis is posed by specified factors as: printout, distribution, cash handling, convoys, counting, exchange of banknotes and coins. Moreover, there is besides the phenomenon of money counterfeiting (although this is far more uncommon than in the past). Cash has been attributed to associations with the grey region and is besides frequently demonised as a means of financing terrorism and making illegal transactions. Cash displacement is so advertised as the simplest way to seal the taxation system, but this kind of action is not a systemic solution that eliminates the problem of unfair practices, but only a possible limitation of the area in which pathological behaviour may occur.
In crime-related matters, while abstaging payments by cards, but for the sake of order and stripping off the criminogenic image of cash, it should be pointed out that virtually all taxation frauds and crucial money laundering operations are carried out in a non-cash manner (not by cards, but alternatively by transfers and financial operations).
This is due to the fact that the amounts that are stolen by the VAT mafias are large adequate that they must be transferred in the earlier stages of the operation of the VAT carousel in accordance with the applicable rules.
In the case of VAT fraud, money is transferred to the account of a dishonest individual of his own motion in the form of a refund of the taxation or in the consequence of operations carried out (received by a transfer from a counterparty) and then without payment of VAT is transferred without cash to a place where criminals will freely consume them, for example in a taxation haven. In the case of money laundering by criminal groups, full structures based on electronic money trading are used.
It is besides worth pointing out that online trafficking offences are increasingly dangerous. It needs to be stressed that unfortunately we are utilized to situations where, as a consequence of hacker attacks, full data packages, including the payment and credit card numbers utilized in transactions, enter the internet. A criminal business developed around stolen data – any criminals specialised in data theft and others in attempts to usage it. These are all absent in public discussion costs of non-cash trading.
The view of the costs of cash trading and its criminogenic nature is never compared with the costs of non-cash transactions and its criminal aspects.
Non-cash transactions require comprehensive technological solutions to function. The fact that on a regular basis we do not announcement the full business chain and the technological chain behind the transaction without the participation of cash is simply a substance which requires constant emphasis and information. In fact, the card is an electronic device to be manufactured by plastic and a suitable chip. In addition, terminals made of plastics and metals that operate on the basis of software are needed. It should besides be noted that processing and collection centres, namely computers, servers and decently adapted buildings, are needed to handle the processes of data circulation and collection.
On the margins of the full system, there is the cost of energy essential for the operation of the full system, the handling of transactions on the part of banks, clearing agents and besides the points themselves equipped with terminals. net access is required. It is worth noting that in the case of Bitcoin and another cryptocurrency, the energy consumption aspect is simply a common argument for critics, and in the case of electronic payment handling never appears. These costs are not only economical but besides environmental.
Non-zero labour costs are besides present for electronic payments. Of course, it is not the wage of a cashier and a convoy like cash, but the cost of computer science, a data protection specialist, a cybersecurity specialist and another specialized employees. At the same time, it should be pointed out that financial institutions – e.g. banks besides have crucial human costs associated with card handling. In the first stage, we have an worker who draws up and accepts card applications. Then individual has to order a card to the bank, individual has to deliver it, individual has to physically pack it and send it to the client in the end. The card must be advertised, it is up to you to make a hotline as well as accompanying infrastructure.
On the user side, the cost of the card fee as well as the fees for transactions made in the bank account. Moreover, it is rather common to have respective bank accounts, which usually involves having respective cards dedicated to them and bearing fees. The business side has the cost of renting terminals and the economical burden of payments made to them by customers to payment operators.
There are besides a number of problems with card use, specified as stealing funds through physical card theft or copying data and illegal borrowing by credit cards. All of this creates costs and economical risks on the part of users that are incomparably greater than in the case of cash. In case of cash theft, a tiny sum in the wallet usually disappears, and if there was a card in the wallet, there could be a failure of far larger amounts. In addition, in case of loss, the card should be blocked (and possibly requested a fresh one). This creates on the user's side the essential emotional cost, the cost of the time spent.
What is presented as a cash defect is besides its advantage. Cash ensures the anonymity of transactions without brokering any entity (except for the marginal function of the money issuer). This leads to a deficiency of any trace, apart from the inclusion in the taxation sales records, which only shows that there has been a sale.
Cash is the best way to defend privacy, both from surveillance by the state, corporations and intermediaries collecting data related to transactions. Cash facilitates the rational management of individual finances. It besides has a profound impact on the learning of saving children and young people.
The argument for the fact that the cash turnover is good and represents value for the free and self-respecting individualism of society is the fact that the People's Republic of China, the largest totalitarian state in the planet fights it and actively promotes non-cash solutions.
Cash turnover besides ensures the safety of the state. The Central Bank of Sweden, a country which has been a cashless avant-garde so far, stated that the elimination of cash trading poses a threat to public security. Cash turnover is simply a kind of safety valve in crisis situations – a threat to state security, natural disasters, failures of payment and energy systems. The Swedes noted that cash payments represent a circumstantial economical power of the issuing country. The electronisation of payments actually puts this power on private corporations and systems.
Crisis situations in Poland specified as Covid-19 and the outbreak of war in Ukraine showed that Poles at times of danger and uncertainty put money on cash alternatively than electronic payment systems.
Situation in another countries
Poland against the background of countries with more developed economies is simply a circumstantial place in terms of payment culture. In our country, due to the long-term delays in the banking and financial system, due to the economy centrally planned during the PRL period, it was essential to build modern services from scratch. Reached for the latest and latest solutions.
One of the areas that has become subject to accelerated improvement are payments, specifically their electronicisation and the spread of payments by wire transfers and cards. Examples from abroad should be cited. In the U.S., the phenomenon is presently losing its popularity, but we can inactive see that the usage of payment cheques is inactive common. In Poland checks were a marginal form of payment, and presently they are virtually absent.
Moreover, in our western neighbours – for example Germans, but another countries of Western Europe can besides be mentioned – payment with the card was not widely accepted, now this anticipation has spread in large cities and is being expanded, but in smaller towns there is inactive no or implementation of specified a form of payment meets with reluctance and resistance. In particular, tiny catering outlets and shops are curious in receiving cash payments.
In a number of Anglo-Saxon countries, specified as the USA, Australia, fresh Zealand, the average view is simply a card informing about the anticipation of payment only in cash.
What is peculiarly interesting, many of them besides include ATMs that you can usage and retreat money to pay in cash. frequently ATMs are owned or leased by these companies. This means that tiny business owners do not bear the cost of terminal charges, nor do they charge them for card payment itself, and at the same time receive a commission on cash withdrawals.
Some businesses in the US, for example, apply an additional component of the policy to reduce card payments and to pay fees. This is an increase in prices for this kind of payment. In particular, this mechanics eliminates card payments in low value transactions.
Ming’s Supermarket, USA, photo. Flickr / Chris Devers / CC BY-NC-ND 2.0It is clear that Poland is in the avant-garde of countries with wide payment possibilities. In addition, mechanisms specified as, for example, charging the additional amount to the price referred to above cannot be applied due to the fact that EU law prohibits the charging of fees for selected forms of payment for SEPA cards, credit cards and transfers. It besides prohibits charging fees exceeding the costs incurred for BLIC or PayByLink.
Taxation of transaction execution
Turning to the taxation aspects of non-cash payments, the transactions themselves make the money circulation transparent to the services. In this process, banks and another financial institutions are partners who supply account data and client information and activities. Regulatory forcing entrepreneurs and consumers to pay without cash facilitates automated control processes. Unfortunately, the fact is besides that the elimination of cash carries risks of supervision, surveillance and abuse, and that the very forcing of entrepreneurs and citizens themselves into an increasingly lower allowed payment limit is burdensome and clearly impairs economical and economical freedom.
The argument about the good impact of non-cash trading on the taxation strategy is seemingly correct, but at the same time represents a immense simplification and ignoring a number of aspects of reality.
The grey region and the non-payment of taxes do not consequence from the fact that there is cash traded, but from systemic weaknesses.
Such systemic weaknesses are, for example, the deficiency of assurance of taxpayers in the fairness of taxes paid, boycotting of state institutions, failure of the control strategy to fulfil the obligations of taxpayers, functioning of criminal groups, incorrect plan of taxation. All these problems, alternatively of solving them, can only gain a surface simplification of any symptoms.
At the same time, it should be pointed out that the digitisation of payments is simply a natural phenomenon. It is more convenient to transfer a fewer clicks than to carry with them in suitcases to a counterparty (if possible, due to the fact that it is now prohibited between traders). Online purchases with the anticipation of payment via card, Blika or PayPala are convenient. There are a number of goods for which you can pay only digitally, specified as computer games in virtual stores and on gaming platforms. In the real world, non-cash payments can be seen, for example, in large discount networks. A fewer years ago, erstwhile we entered the insect marketplace in the logo, we saw respective cash registers open, and in each of them a cashier or cashier. presently the standard is open 1 cashier and respective automatic cashiers (in any types you can pay in cash), and the full is frequently served by 1 person.
Non-cash payments make gross on the part of card operators, payment systems, as well as a broadly understood payment business (terminals, payment operators, banks) and operators.
At this point it is worth giving circumstantial numbers. According to the latest Information on payment cards for the 4th fourth of 2024 developed by the NBP on the basis of data from card publishers, 2.7 billion transactions were carried out utilizing payment cards in the 4th fourth of 2024, with a full value of PLN 334.3 billion.
Non-cash transactions were as much as 2.5 billion among them, amounting to PLN 198,1 billion. Accepting the average value of the commission (which consists of an intercharge fee of 0.2% for debit cards and 0.3% for credit cards, a strategy fee and a clearing agent's margin) of 0.5% of the transaction value (PLN 0.005 × 198.1 billion), this gives the manufacture an income of PLN 990.5 million, while accepting a commission of PLN 0.8% (PLN 0.0008 × 198.1 billion) – PLN 1 584.8 million.
These are quarterly amounts and relate only to non-cash transactions; it should be borne in head that this is income and not income – it will be reduced by costs and the full commission value is shared between different entities in the transaction chain.
At the same time, it is essential to point out the gross of cash operators. Their value in this period amounted to PLN 136.3 billion with about 120 million transactions. Assuming an average cost of cash withdrawal operations of PLN 1.5 (this is very different between banks and the amounts of withdrawals), this will give operators revenues of PLN 180 million, or 0.13% of the transaction value.
It is so clear that the non-cash payment section has powerful revenues, which are in fact at the expense of the remainder of the economy. This creates an acceptable social ground for creating a modern, anticipated and unchangeable origin of taxation revenue. In addition, it will let the return of part of the funds to the budget which the State is losing as an issuer of money to private payment service providers.
The issue to be noted is the anticipation of a possible transfer of card payment tax. The long-established phenomenon is that, in the case of a levy on a single entity, the taxation burden can actually be borne by another entity. The transferability of the taxation was the subject of more research. There are 2 forms of shiftability: ‘forward’ – erstwhile the purchaser is charged with the transferred taxation by raising its prices or ‘backwards’ – erstwhile the costs borne by the payer are reduced while carrying out a peculiar activity.
In the field of transferability, it is referred to as total, partial and excessive. The phenomenon most commonly observed and commonly found in the collection of social taxation is the "forward forward" shift of a full nature. However, this does not should be a rule, as the form and scope depend on the subject substance of taxation and very individual factors specified as its construction or the formation of the marketplace into which the taxation interferes.
Looking at the card payment tax, on the 1 hand, there is simply a strong likelihood that the taxation will be passed on in any way by raising, for example, the fees related to payments made. This is mainly indicated by the nature of the sector which is not willing to limit its profits due to the imposition of public burdens on it. On the another hand, it is not essential to do so, but it is in the industry's interest that the number of transactions and their value increase alternatively than decrease. Raising fees could discourage customers from paying with cards. erstwhile attempting to transfer tax, large corporations, with discount networks and hypermarkets, would be most affected as customers have widely available self-service money and have late been encouraged and accustomed to paying cards, which has contributed to reducing worker costs. They are not entities that will easy accept specified action of the payment industry.
Moreover, any additional charge to compensate for manufacture taxation could have a negative effect on the manufacture itself in the form of a marketplace reduction, e.g. in the event of an increase in card issuing fees or its possession. In specified a situation, people would be willing to quit a fewer cards for 1 or more cash payments, and where necessary, do not usage a card just bank transfers.
There is simply a hazard that the taxation would to any degree be passed on to customers making payments by cards or traders erstwhile they were accepted. However, this is uncertain, as specified action could yet have additional negative effects on the industry. Furthermore, it should be pointed out that the designation and publicity of taxation transfers could consequence in more frequent recourse to cash.
It is worth to mention here an example of a recycling charge, which in fact changed Poles' habits in the area of packaging purchases through the multiple usage of 1 commercial alternatively of utilizing a fresh 1 at each purchase. The cash payment sector would surely not want akin changes in payment habits. This gives emergence to the presumption that the transfer of taxation on consumers would not occur, or would only be partial, and that its burden would be mainly on card payments business.
A non-cash payment taxation would be highly easy to collect from the very essence of the events to be taxed.
All events are recorded and the taxation would charge a tiny number of entities that operate on a highly regulated market. As regards structural aspects, each taxation must have elements specified as:
1) Subject substance of taxation, 2) subject substance of taxation, 3) basis of taxation, 4) rates and scales of taxation.
Subject substance of the tax
The subject of the taxation is what the taxation is paid on. The catalog of possible taxation items is virtually unlimited. 1 common subject of the taxation is simply a circumstantial action, e.g. to get income, to carry out legal acts or to conduct certain behaviour. If you want to taxation card payments, you should consider the execution of an electronic payment via a card. The minute erstwhile the funds are entered in the account of the payee should be considered as the execution of the transaction.
At the same time, it should be mentioned that there is simply a second kind of card transaction, i.e. a cash transaction, consisting of cash withdrawals from ATMs, bank cash withdrawals and cash back payments. specified transactions would not be taxed. Leaving them as tax-free is intended to let people not to bear the possible economical burden of the taxation erstwhile attempting to transfer it, and, above all, to let the free and unfettered choice of cash to be introduced into the economical circulation.
Tax entity
As a taxable person, the taxable individual is defined as the taxable individual who is liable for the settlement and fulfilment of his own work through payment.
In the case of a card transaction tax, it would be easiest to specify card organisations, specified as Visa, Mastercard, having access to transaction registers.
Card organizations licence both clearing agents and associations banks issuing cards that are their associate institutions. Granting the position of a payer to card organizations is besides a legitimate solution due to the fact that cards issued by card organisations are ‘twisted’ to electronic payment systems specified as Apple Pay or Google Pay.
Of course, there is besides a question of card organizations that are operators of payment cards of a more niche character, which will origin a problem with the Polish taxation jurisdiction. In specified a case, if the card organization does not have a legal individual representing it or a branch in Poland, it would be reasonable to grant the payer position to the clearing agent serving their transactions in Poland.
At the same time, account should be taken of mobile payment systems specified as the most popular BLIC. It has additional functionality beyond paying the card, allowing to make payments without its use, which is an additional problem in the plan of the tax. In the case of mobile payment systems, making transfers to a telephone number and generating checks with a digital code should not fall within the scope of the plan of the proposed solution, which does not preclude it from being subject to another akin plan tax, the plan of which will take better account of the specificity of specified payments.
Tax base
In case of non-cash card payments, fees specified as intercharge, strategy fee or clearing agent margin etc. are charged. These fees do not usually exceed 1% of the transaction value (but may in any cases scope up to 1.5%) – they are presently mostly oscillating between 0.5 and 0.8% of the transaction value. A crucial number of transactions with a percent of the low fees associated with a single transaction yet make crucial sums of money.
The most apparent solution is to base the taxation base on the value of the transaction. Large amounts flow through the strategy – the taxation base increases, tiny amounts flow through the strategy – it falls. At the same time, fees based on transaction values already be in the system. The addition of the State as the next associate in the process seems to be a natural solution.
Tax rate
The rate of taxation should be defined as a fraction of the value of the transactions carried out. The issue of the selection of a circumstantial rate should be developed by econometrics of the Ministry of Finance after consultation with the NBP. At the same time, it appears that the maximum taxation rate should not exceed 0.5% of the value of a single transaction so that the share of the taxation does not exceed the share of another charges in charge of the transaction. However, a higher rate should not be excluded as it is up to the political decision and to the request for fresh funds and capacity to pay that rate.
However, the rate could initially be 0.2% of the value of payments in order not to origin a marketplace distortion.
The introduction of a rolling taxation rate which will gradually increase over respective years has the chance to prevent taxation being passed on to consumers and businesses and to give manufacture time to adapt to fresh realities, as in the case of, for example, the alleged excise map.
Preliminary estimation of receipts
Taking – in a very simplistic way – a hypothetical taxation rate of 0.2% of the value of all transactions and data for the 4th fourth of 2024, presented by the NBP, that the value of non-cash transactions (cards) amounted to PLN 198.1 billion, could make taxation liabilities of about PLN 396.2 million quarterly, which are easy collected, simple and inexpensive in the collection and practically unsuitable for taxation optimization.
It should be stressed that this is simply a quarterly value – taking the estimation that the value of non-cash transactions would stay at the same level throughout the year, it would be possible to get over PLN 1584.8 million per year.
Based on these powerfully simplified and viewable calculations, the introduction of specified a simple fiscal mechanics could consequence in taxation revenues at a advanced level – already in the basic version, in the first year of application.
Cross-border issues and problems arising under EU law
The main challenge of the proposed solutions is the cross-border taxation issue. The basic question is: do you taxation payments made abroad by Polish card holders and besides taxation payments made to abroad entities by Polish users?.
There is besides a question of whether and how to taxation payments of abroad card users to Polish customers. The most effective way to solve these problems is to introduce only intra-national taxation, i.e. payment in Poland to the Polish recipient. It solves the problem of cross-borderity. At the same time, it makes taxation implementation much easier.
On the issue of EU law, the proposed proposals require a broader analysis, in peculiar in terms of compliance with the freedoms of the common market. However, the proposals described above do not affect the free movement of capital between associate States nor discriminate between companies from another EU countries.
