The Polish tax system is convoluted and complicated, as evidenced by the results of annual tax system rankings. Constantly announced new changes, intended to "patch" tax law shortcomings, only make the laws bloat and become increasingly difficult to understand.
However, just because the Polish tax system is complicated doesn't mean you can't pay low taxes in Poland. You can. Several tools are available to make it easier. Here are three of the most popular examples.
IP BOX relief
One of our clients, a company in the broadly defined IT industry, exceeded €2 million in revenue in the second half of the year. As a result, not only will it no longer benefit from the lower CIT rate (9%) in the next tax year, but it will also be required to pay advances for the entire current tax year at a rate of 19%. Since its inception, the company has maintained accounting records that allow it to allocate revenue and costs to each computer program it produces.
On behalf of the company, we requested a tax ruling confirming its eligibility for the IP BOX tax relief. As a result, the company is still unable to use the 9% CIT rate, but is able to use the 5% rate.
Estonian CIT
This solution allows for tax-free reinvestment of profits. It worked well for our client in the construction industry. They own several companies, but the most profitable one operated as a limited liability partnership (LLP). This resulted in double taxation of profits. Tax was first paid by the limited partnership and then by its partners, including the LLC. In this case, the structure first needed to be simplified. The limited partnership became a LLC, and its partners were exclusively individuals. It also turned out that the company reinvested most of its profits for further operations. Therefore, they implemented Estonian corporate income tax (CIT). Ultimately, despite paying out a portion of the profit as dividends, the tax burden on the business decreased significantly.
Family Foundation
A family foundation not only serves to ensure business succession but can also improve its operations. Our client operating in the renewable energy sector decided to implement it. He is conducting several investments, each of which is the responsibility of a different company. Previously, these were financed with loans from the main shareholder. The special purpose vehicles did not pay the PCC tax on loans, but the lender was required to pay a 19% tax on interest received. They also paid tax on dividends received. After the introduction of the family foundation, which became the main shareholder of the special purpose vehicles, it no longer pays tax on interest received on loans. Furthermore, it is also exempt from tax on dividends. Therefore, these funds can be used to co-finance further projects cost-free. If the family foundation distributes funds to its beneficiaries, the tax rate will be 15%, instead of the 19% that would apply to dividends received from the company.
This article is for informational purposes only and does not constitute legal advice.
The law is current as of December 15, 2025.
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