28.3 Contingent receivables

As at the reporting date, the PGE Capital Group held PLN 5 million in contingent receivables resulting from imbalance between purchases and sales of energy in the domestic market (PLN 33 million in the comparative period) and from potential return of overpaid excise tax in the amount of PLN 72 million. The Group awaits the Supreme Administrative Court’s decision on what excise tax rate should be applied to settle the excise tax relief for the redemption of property rights arising from renewable energy sources before January 1, 2019.

In the opinion of the PGE Capital Group, the rate in force at the time of the sales of electricity generated from renewable energy sources to the end user, i.e. 20 PLN/MWh, should be applied to settle the said relief. This position was sustained by the judgement of the Provincial Administrative Court in Rzeszów of October 8, 2019.

On November 20, 2019, the tax authority filed a cassation appeal against the above-mentioned judgement of the Provincial Administrative Court.