Taxes in Poland for Companies

Taxes in Poland for companies: key rates and limits in 2026

How is corporate income tax calculated in Poland?

A company with its registered office or management in Poland is taxed on its worldwide income under Article 3(1) of the ustawa o podatku dochodowym od osób prawnych (the Polish CIT Act). The standard rate is 19%. Taxable profit is broadly taxable revenue less tax-deductible costs, with separate rules for capital gains and a range of specific limitations and adjustments.

Under Article 15(1) of the CIT Act, a cost is tax-deductible if it is incurred to earn or secure revenue or to preserve its source, and it is not on the list of excluded items in Article 16(1). The cost must be documented. Intercompany service charges must reflect services actually performed and be priced at arm's length. Debt financing costs are limited separately under Article 15c of the CIT Act.

The 9% rate can be relevant for smaller operating companies. Eligibility depends on the statutory revenue tests, taxpayer status and the exclusions described above. Our article on the conditions of the 9% CIT rate explains the tests in detail.

For foreign groups, the question that usually drives the Polish tax result is where functions, people and risks sit, and whether the Polish entity earns an arm's length return for what it actually does.

Can a Polish subsidiary owned by a foreign company use Estonian CIT?

Generally no, because the shareholder is a company. A foreign shareholder who is a natural person does not by itself exclude the regime. Poland offers an alternative corporate tax regime known as Estonian CIT. Under it, retained profits are generally not taxed until a distribution or another taxable event occurs. Tax can still arise during the year on statutory categories such as hidden profits and expenditure unrelated to business activity.

Under Article 28o(1) of the CIT Act, the rate is 10% for a small taxpayer or a company starting its activity and 20% for other taxpayers in the regime.

Estonian CIT is more relevant to owner-managed structures with a simple ownership chain than to multinational subsidiary structures.

How is withholding tax charged on dividends, interest and royalties?

Polish domestic withholding tax rates are 19% for dividends under Article 22(1) of the CIT Act and 20% for specified interest and royalty payments under Article 21(1)(1). A double tax treaty or an EU/EEA exemption can reduce or eliminate Polish WHT if the statutory conditions are met.

Polish WHT procedures also require payer due diligence. Under Article 26(2e) of the CIT Act, where dividends, interest or royalties paid to the same related non-resident exceed 2 000 000 PLN in the payer's tax year, the payer generally withholds tax at the domestic rate on the excess, without applying the exemption or the treaty rate. The recipient can then apply for a refund. The obligation does not arise where the payer files a WH-OSC statement or holds an opinion on the application of preferences, and statutory exclusions apply to specified payments.

KSeF, JPK_V7 and JPK_KR_PD: what is reported electronically?

Active VAT taxpayers file JPK_V7M electronically every month. Small taxpayers can, subject to conditions, opt for quarterly VAT settlement (JPK_V7K), but the records part is still sent monthly and only the declaration part is quarterly. We settle VAT monthly for our clients. The tax administration can match invoicing, VAT and banking data across these systems.

KSeF in 2026

Mandatory KSeF e-invoicing was introduced in stages. According to the Ministry of Finance, the largest taxpayers entered the system from 1 February 2026 and most remaining taxpayers within the mandatory scope from 1 April 2026. A limited transition remains until the end of 2026 for certain low-volume issuers.

A foreign company with a Polish VAT number is not automatically required to issue through KSeF. A foreign entity with neither a business establishment nor a fixed establishment in Poland is outside the mandatory issuing scope. The same can apply where a Polish fixed establishment exists but does not participate in the relevant supply.

Monthly JPK_V7M filing and VAT-UE reporting form part of our VAT compliance service for foreign companies.

JPK_KR_PD and JPK_ST_KR

For tax years beginning after 31 December 2025, the Ministry of Finance states that the income-tax JPK obligation covers, among others, CIT taxpayers required to submit monthly JPK_V7. Their accounting systems should therefore capture the data needed for the annual JPK_KR_PD and related structures for 2026. This is part of the statutory bookkeeping we run for Polish subsidiaries.

VAT in Poland

Polish VAT follows the EU VAT framework. The standard rate is 23%, with reduced rates of 8%, 5% and 0% for specified supplies.

For international businesses, most VAT work concerns where a transaction is taxable, whether Polish registration is required, whether reverse charge or OSS changes the result, how imports and stock movements are structured and what documentation supports a 0% intra-Community supply or export.

After registration, recurring compliance normally includes VAT records and monthly JPK_V7M, plus VAT-UE where relevant. Under Article 87(2) of the ustawa o VAT, the standard VAT refund deadline is 40 days from the date the JPK_VAT with declaration is filed. The Ministry of Finance states that it applies to settlement periods from 1 February 2026. The tax office can extend the deadline to verify the refund claim.

Tax year, CIT-8 and annual financial statements

A Polish company's tax year is often the calendar year. A different tax year can be selected where the statutory requirements are met.

Under Article 27(1) of the CIT Act, the annual CIT-8 return and the related annual CIT payment are due by the end of the third month following the end of the tax year. Companies subject to Polish accounting law must also prepare annual financial statements and, where required, file them electronically with the National Court Register, KRS.

For foreign-owned companies, the year-end process should be planned with group reporting. Polish statutory accounts, CIT calculations, transfer-pricing data and group consolidation packages often use different deadlines and data formats.

Accounting and recurring tax compliance

A Polish company needs statutory accounting that complies with Polish accounting and tax rules. A German, Austrian or group ERP can be part of the process, but it does not by itself replace the Polish statutory ledger, Polish tax mappings and local filing structures.

The monthly close should run as one controlled process covering source documents, KSeF and non-KSeF invoices, bank transactions, payroll, VAT, intercompany postings, fixed assets and tax adjustments.

Subsidiary, branch or foreign company: which tax footprint fits?

A Polish subsidiary is a separate legal entity and a separate Polish CIT taxpayer. A registered branch remains part of the foreign head office and requires profit attribution to the Polish permanent establishment. A foreign company can also have Polish VAT or payroll obligations without creating a Polish subsidiary.

The choice depends on contracts, personnel, assets, decision-making, expected duration of the Polish activity, regulatory needs, financing and the way profits will be repatriated.

Can a foreign company register for VAT without a Polish company?

Yes. Many foreign businesses register their existing foreign entity for Polish VAT without incorporating a Polish company. Typical cases include Polish inventory, imports, local movement of goods and certain domestic supplies.

VAT registration alone does not create a CIT permanent establishment. It also does not prove that no permanent establishment exists. VAT fixed establishment and CIT permanent establishment are separate concepts and must be analysed against the actual facts.

When does a foreign company have a permanent establishment in Poland?

A foreign company becomes subject to Polish CIT on profits attributable to a Polish permanent establishment, even without a Polish subsidiary. The applicable double tax treaty must always be checked.

Common PE risk areas include a fixed place of business at the company's disposal, construction or installation activity exceeding the relevant treaty threshold and dependent-agent arrangements. Local personnel can be relevant even without a formal Polish office, depending on what they do, what authority they exercise and whether a place in Poland is effectively available to the foreign business.

Setting up a Polish company

For many foreign corporate investors, the standard legal vehicle is the Polish limited liability company, spółka z ograniczoną odpowiedzialnością, usually abbreviated as sp. z o.o. Under Article 154 § 1 of the Commercial Companies Code, the minimum share capital is 5 000 PLN.

A straightforward company can often be registered quickly, particularly where the S24 online route is available and its standard documentation fits the project. Registration is only one part of market entry. Banking, beneficial-owner filing, accounting, tax registrations, signing rights and KSeF access must also be organised before the company is operational.

A branch can be the better choice in some projects, especially where the foreign head office is intended to remain the direct contracting party. It is not automatically simpler from an accounting or tax perspective.

First registrations after incorporation

After KRS registration, the company completes the registrations and operational setup relevant to its facts. This typically includes the beneficial-owner filing in CRBR, supplementary tax data where required, bank-account setup, accounting onboarding and VAT registration where the business model requires it.

ZUS registration is driven by the company's actual social-security obligations, for example employment or other insured remuneration arrangements. It does not follow automatically from incorporation.

Payroll, employees and B2B contractors

A Polish employer calculates and remits payroll tax advances and social-security contributions and maintains the required employment documentation. Occupational health examinations, health and safety obligations and personnel files form part of the operating process.

The employer finances its own share of the pension and disability contributions and the whole accident contribution, plus further items such as PPK where applicable. The total cost depends on the employee and employer profile, so we calculate it per case rather than as a flat percentage.

B2B cooperation with independent professionals is common in Poland, particularly in IT and technical sectors. The contract label is not decisive. If the individual works in conditions resembling employment, labour-law, tax and social-security classification risks need to be assessed.

Transfer pricing in Poland

Transactions between a Polish entity and related foreign group companies must be priced on an arm's length basis. This applies even where the local-file threshold is not exceeded.

Under Article 11k(2) of the CIT Act, the local-documentation thresholds for standard controlled transactions are 10 000 000 PLN for goods transactions, 10 000 000 PLN for financial transactions, 2 000 000 PLN for services and 2 000 000 PLN for other transactions. Special rules and lower thresholds apply in specific cases.

Where a local file is required, the statutory deadline is the end of the tenth month after the tax year. TPR reporting is a separate obligation. Intercompany agreements, allocation keys and the economic rationale should be set before year-end rather than reconstructed after the fact.

Polish bank account and AML

A Polish bank account is not a universal statutory condition for the existence of a Polish company or for filing VAT-R. It is often operationally important.

Split payment uses a dedicated VAT account linked to the Polish banking infrastructure. Polish counterparties also use the White List of VAT taxpayers to verify business accounts. VAT refunds and recurring domestic payments are therefore easier to run with a Polish business account.

Bank KYC and AML review is separate from company registration. International groups should expect questions about beneficial owners, group structure, expected transactions, countries involved and the commercial purpose of the Polish entity.

Management board, governance and tax residence

Polish company law does not generally require management board members of a sp. z o.o. to be Polish citizens or Polish residents. A foreign management board is therefore legally possible.

Tax residence and permanent-establishment questions depend on where management and business functions are actually exercised. For cross-border groups, board decisions, powers of attorney, signing rules and the location of key management processes should be consistent with the intended structure.

Illustrative examples

The scenarios below are composites for illustration. They do not describe a specific client.

Frequently asked questions