An operations director can work with a company as an entrepreneur on JDG (sole proprietorship), but in this case the type of contract matters more than for most B2B arrangements. If the contract is essentially a managerial contract, the revenue does not even reach the business activity — and then ryczałt (lump-sum tax on recorded revenue) and the flat tax drop out. Below, in order, we cover: the type of contract, the PKD 2025 code, the form of taxation (15% ryczałt for management advisory), VAT and costs, as of 2026.
Advisory, management or managerial contract
The PIT Act classifies as personally performed activity the revenues from enterprise management agreements, managerial contracts and similar agreements — including when the contract is concluded within business activity (Article 13(9)). Fees of members of management boards and other bodies of legal persons also belong to the same source (Article 13(7)).
In practice, this means three different scenarios for a person serving as operations director:
| Model | Source of revenue | Effect |
|---|---|---|
| Advisory and project services (process reorganisation, implementations, operational audits) | business activity | available: tax scale, flat tax, ryczałt |
| Enterprise management agreement or managerial contract | personally performed activity | taxed on the scale, no flat tax or ryczałt |
| Appointment to a company's management board | personally performed activity | as above; a JDG invoice does not change this |
The dividing line does not depend on the title of the contract but on its content. A contract in which the entrepreneur takes over running the whole company or a separate part of it, with decision-making powers and liability towards the client, comes close to a managerial contract. An advisory project with a defined result, schedule and the contractor's own risk remains a service within JDG. Article 5b of the PIT Act helps with classification: an activity is not business activity if, cumulatively, the client bears liability towards third parties, the work is performed under their direction in the place and time they designate, and the contractor does not bear economic risk.
The former-employer rule
A common scenario: the operations director moves from an employment contract to a B2B contract with the same company. The PIT Act removes the right to the flat tax in the year in which the entrepreneur provides services to a current or former employer corresponding to work performed under an employment contract in the same year. The Ryczałt Act is stricter — it also reaches back to employment duties from the previous year. Someone who leaves an employment contract in December and from January does the same work on JDG for the same entity cannot use ryczałt that year.
PKD 2025 code: 70.20.Z
In PKD 2025 the subclass 70.20.Z covers business and management consultancy. The GUS explanations list here, among others, strategic planning, process reorganisation, change management, cost reduction, production planning and control, as well as the activity of a managing unit involving director or managerial functions. This is usually the best primary code for an operations director on JDG.
Subclass 70.10.A (head offices) covers supervision and management of other units in the same group — it suits holding companies rather than an independent manager. If, in addition to management, staff training is provided, 85.59.B can be added. The general rules for choosing codes are described in the guide how to choose a PKD code.
Form of taxation: flat tax, scale or 15% ryczałt
If the revenue is business revenue, three forms are available:
- 15% ryczałt — the Act lists this rate for the services of head offices and management-related consultancy (PKWiU ex section 70). This is the most common rate for an operations director; the lower 8.5% would apply only to services outside these groups.
- 19% flat tax (podatek liniowy) — with costs and a 4.9% health contribution on income; often chosen with high daily rates and significant costs (travel, vehicle, team).
- 12% and 32% scale — with a PLN 30,000 tax-free amount; worthwhile rather at lower income levels.
Comparison example
In 2026 an operations director invoices PLN 35,000 a month (PLN 420,000 a year) and has PLN 40,000 of annual costs. Under ryczałt the tax is about PLN 63,000 (15% of revenue, before deducting part of the health contribution), and the health contribution in the highest bracket is PLN 1,495.04 per month. Under the flat tax, the base is about PLN 380,000 of income (before ZUS contributions), giving about PLN 72,000 of tax and a 4.9% health contribution on income. The difference depends on the cost level — at PLN 80,000–100,000 of annual costs the advantage of ryczałt quickly disappears. A broader comparison of forms is in the article on the 19% flat tax.
VAT: advisory outside turnover-based exemption
Advisory services are excluded from the turnover-based VAT exemption of PLN 240,000. An operations director providing advisory services should therefore register as an active VAT payer before the first sale, regardless of turnover, and invoice the services at the 23% rate. For foreign clients, the place of taxation of services to businesses is as a rule in the buyer's country.
It is different under a managerial contract, where the client bears liability towards third parties and the contract sets out the terms of work and remuneration — the VAT Act does not treat such activity as independent business activity.
Costs that can usually be defended
Under the flat tax or the scale, a cost is anything that serves revenue and is not excluded by the Act. For an operations director these typically include:
- equipment and software for project management and reporting;
- travel to the client's plants and branches, accommodation, tickets;
- training and certifications related to operations management;
- legal and accounting services, professional liability insurance;
- a car — with value limits and proportions for mixed use.
Representation expenses (e.g. dinners with contractors) and personal expenses are not costs. Under ryczałt, costs do not reduce the tax at all.
What to watch out for in the contract
- Describe the scope as services with a defined result and measurable goals, not as "holding a function" in the structure.
- Regulate the contractor's liability — contractual penalties, professional liability insurance.
- Preserve freedom to organise the work and the possibility of working for other clients.
- If appointment to the management board is involved, settle that function separately, outside JDG invoices.
Employment-like elements in a B2B contract also raise the risk of the arrangement being challenged — we describe this in the article B2B contract reclassified as employment.
How Good Balance can help
We help managers assess whether their contract fits within business activity, choose the form of taxation and register for VAT. The handling of registration and settlements of a sole proprietorship is described on the page JDG registration and running.