28.3 Contingent receivables
At the reporting date, the Group has contingent receivables of PLN 120 million (PLN 72 million in the comparative period) for the potential refund of the excise tax overpayment. The Group is awaiting a ruling from the Supreme Administrative Court on what excise duty rate should be applied to account for the excise duty relief on the redemption of Energy Origin Rights generated from renewable energy sources before 1 January 2019.
According to PGE Group, this relief should be settled using the rate applicable at the time the electricity generated from renewable sources is sold to the end customer, i.e. 20 PLN/MWh. This was confirmed in a ruling by the Voivodship Administrative Court in Rzeszów of October 8, 2019.
The tax authority issued a cassation appeal against this ruling by the Voivodship Administrative Court on November 20, 2019.