9% CIT Rate in Poland in 2026: Rules, Limits and Who Qualifies

Published 7 April 2023 · Last updated 12 October 2026 · Jerzy Gaweł, Tax Advisor

The 9% corporate income tax (CIT) rate in Poland may apply to small taxpayers and to companies starting business activity. It is set by Article 19(1)(2) of the ustawa o podatku dochodowym od osób prawnych (the Polish CIT Act). The rate is not automatic. The company must meet the statutory conditions, and the 9% rate never applies to capital gains.

The standard Polish CIT rate is 19% under Article 19(1)(1) of the CIT Act. For an overview of all taxes a Polish company pays, see our guide to corporate income tax and other taxes in Poland.

Quick answer. For 2026, a Polish company may use the 9% CIT rate only if it meets the statutory conditions. For a calendar-year taxpayer, the key limits are 8,517,000 PLN of previous-year sales revenue including VAT for small taxpayer status and 8,431,000 PLN of current-year revenue for the 9% rate. Capital gains are taxed at 19%.

What this article covers

The 9% CIT rate needs two separate conditions met at the same time: small taxpayer or start-up status, and staying under the current-year revenue limit.
Two different 2026 revenue limits apply: 8,517,000 PLN (previous-year, small taxpayer status) and 8,431,000 PLN (current-year, 9% eligibility).
Capital gains, including dividends received, tax capital groups and some reorganised entities are excluded from the 9% rate regardless of revenue.
Exceeding the current-year limit switches CIT advances to 19% from that month or quarter onward. The annual result cannot be split between the two rates.
The NSA, Poland’s Supreme Administrative Court, held in April 2026 that no proportional split is possible once the threshold is exceeded.

In this article

Who qualifies for the 9% CIT rate in Poland?
Revenue limits for the 9% CIT rate in Poland in 2026
Does the 9% CIT rate apply to sp. z o.o.?
What is excluded from the 9% rate?
Advance CIT payments in practice
What happens when you exceed the current-year limit?
FAQ

Who qualifies for the 9% CIT rate in Poland?

A company qualifies only if it meets two separate conditions at the same time. Check both conditions before applying the lower rate.

Condition A, small taxpayer or taxpayer starting business activity. The company must be a small taxpayer or a taxpayer starting business activity. Small taxpayer status is defined in Article 4a(10) of the CIT Act and is based on previous-year sales revenue, including VAT. The 2026 limit for small taxpayer status is 8,517,000 PLN. Further rules for this condition are in Article 19(1d) and (1e) of the CIT Act.

Condition B, current-year revenue limit. Under Article 19(1)(2) of the CIT Act, the company must also stay within the current-year revenue limit. For a taxpayer whose tax year starts on 1 January 2026 and lasts 12 months, the limit is 8,431,000 PLN.

A company may meet the small taxpayer test based on the previous year and still lose the 9% rate for the current tax year if it exceeds the current-year limit.

Revenue limits for the 9% CIT rate in Poland in 2026

The two limits are often confused. They are calculated differently and serve different purposes.

Previous-year limit, small taxpayer status

Determines whether the company enters the year as a small taxpayer.

Sales revenue including VAT
Based on the previous tax year
For 2026: 8,517,000 PLN

Current-year limit, 9% CIT eligibility

Determines whether the company may use the 9% rate in the current tax year.

Current-year revenue for CIT purposes
Separate from the small taxpayer test
For a 12-month calendar year in 2026: 8,431,000 PLN

Tax years other than 12 months. If the tax year is longer or shorter than 12 months, the current-year limit is adjusted proportionally. For a standard 12-month calendar tax year beginning on 1 January 2026, the limit is 8,431,000 PLN.

Official reference. The Ministry of Finance publishes both 2026 limits. See the official CIT rates and limits.

Does the 9% CIT rate apply to sp. z o.o.?

Yes. A Polish limited liability company (spółka z ograniczoną odpowiedzialnością, or sp. z o.o.) is a CIT taxpayer and may use the 9% rate if the statutory conditions are met.

The legal form itself does not block the 9% rate. What matters is the company’s revenue, the type of income, its status as a small taxpayer or a taxpayer starting business activity, and the statutory exclusions.

What is excluded from the 9% rate?

Even if a company meets both revenue conditions, the 9% rate does not apply in every case.

Capital gains: Article 19(1)(2) limits the 9% rate to income other than capital gains. Capital gains, as defined in Article 7b of the CIT Act, are taxed at 19%.
Dividends received: dividends are capital gains income under Article 7b(1)(1)(a), so the 9% rate does not apply to them. Dividends paid by Polish companies are also subject to the separate rules of Article 22, including a 19% rate on revenue and a possible exemption where the statutory conditions are met.

Certain reorganised entities: Article 19(1a) and (1c) of the CIT Act exclude some companies created through transformations, mergers, divisions or specified in-kind contributions, including contributions of an enterprise.
Tax capital groups: Polish tax capital groups cannot use the 9% rate.
Banks: special CIT rates apply to banks from 2026, so those rules fall outside the 9% regime discussed here.

The 9% rate is therefore relevant mainly for ordinary operating income of small or newly established companies. It is not a general reduced rate for all corporate income.

Advance CIT payments in practice

Companies generally pay CIT through monthly advances. Small taxpayers may choose quarterly advances under Article 25(1b) of the CIT Act. Each advance is calculated on cumulative taxable income from the beginning of the tax year.

The use of the 9% rate in advances is governed by Article 25(1g) of the CIT Act. A company that qualifies may apply it to advances for months or quarters in which its revenue from the beginning of the tax year has not exceeded the current-year limit.

The tax authority’s position. In an individual interpretation of 9 October 2025 (0114-KDIP2-2.4010.406.2025.1.ASK), the Dyrektor Krajowej Informacji Skarbowej (Director of KIS, the national tax information authority) took the view that the advance for the month or quarter in which the threshold is exceeded must already be calculated at 19%. The preceding month or quarter is the last period for which the 9% rate may be used. See the individual interpretation.

On that approach, if a monthly taxpayer exceeds the limit in July 2026, June is the last month for which the 9% rate may be used, and the July advance is calculated at 19%.

What happens when you exceed the current-year limit?

If the company exceeds the current-year revenue limit, the 9% annual CIT rate is no longer available. For a standard calendar-year taxpayer in 2026, this means current-year revenue above 8,431,000 PLN.

According to the Director of KIS, the 9% rate may be used for advances only up to the period preceding the period in which the threshold is exceeded.
On the same view, the advance for the month or quarter in which the threshold is exceeded is calculated at the 19% CIT rate.
In the annual CIT calculation, income cannot be divided into a part taxed at 9% and a part taxed at 19% based on the revenue threshold. The NSA confirmed this in the judgment described below.

Example. A company qualifies as a small taxpayer and pays CIT advances at 9% from January to June 2026. In July 2026, its current-year revenue exceeds 8,431,000 PLN. On the position of the Director of KIS, June is the last month for which the 9% rate may be used and the July advance is calculated at 19%. In the annual CIT-8 return (the Polish annual corporate income tax return), the company cannot split its annual operating income between the 9% and 19% rates.

Supreme Administrative Court. In its judgment of 9 April 2026, case II FSK 991/23, the Naczelny Sąd Administracyjny (NSA, the Supreme Administrative Court) held that exceeding the statutory revenue threshold results in loss of the reduced annual rate. According to the NSA, the CIT Act does not allow annual income to be divided between the 9% and 19% rates on this basis. Read the court summary.

Legal status as of 12 October 2026. Tax regulations in Poland change frequently. Verify the current rules before making decisions. This article gives general information, current as at the review date above. Whether a specific company qualifies for the 9% rate requires an engagement with a licensed adviser.

Frequently asked questions

What are the exact 2026 revenue limits for the 9% CIT rate?

The small taxpayer limit is 8,517,000 PLN of previous-year sales revenue including VAT. The current-year limit for the 9% rate is 8,431,000 PLN for a taxpayer whose tax year starts on 1 January 2026 and lasts 12 months.

Does the 9% CIT rate apply to capital gains?

No. The 9% rate applies only to income other than capital gains. Capital gains are taxed at the standard 19% CIT rate.

Can a newly formed sp. z o.o. use the 9% CIT rate from day one?

It can, if it is a taxpayer starting business activity and no statutory exclusion applies. It must also remain within the current-year revenue limit.

Does the 9% CIT rate apply to dividend income?

No. Dividends are capital gains income, so the 9% rate does not apply. Dividends paid by Polish companies are taxed under separate rules, including a 19% rate on revenue and a possible exemption where the statutory conditions are met.

What happens if the company exceeds the 2026 current-year limit?

The company loses the right to the 9% annual CIT rate, and annual income cannot be split between a 9% portion and a 19% portion. According to the Director of KIS, the advance for the period in which the threshold is exceeded already uses the 19% rate.