Impostos a Polònia

Company Tax

19%

Tax Rate For Foreign Companies

Non-residents are only taxed on Polish-sourced income at the same conditions as local companies. Residents are taxed on worldwide income, with foreign tax credit available.
In Poland, a branch office typically qualifies as a Permanent Establishment (PE). Once established, the foreign company is liable to pay Corporate Income Tax (CIT) at the standard rate of 19%, calculated based on the income generated by the Polish branch. To facilitate tax assessment, branches must maintain accounting books containing all relevant data for determining the taxable base, adhering to the same income determination rules as Polish companies. However, in rare instances where a branch proves, according to a double taxation treaty, that its presence doesn't constitute a PE, its profits are exempt from Polish CIT.

Capital Gains Taxation

Polish corporate income tax rules outline specific transactions resulting in capital gains, taxed separately at the standard rate of 19%. Venture capital companies, including limited liability companies and limited partnerships resident in Poland, may qualify for an exemption on gains from transferring shares acquired during 2016-23 in companies engaged in research and development (R&D) activities, subject to meeting specific criteria. Additionally, under certain circumstances, certain investment funds and alternative investment vehicles may also be eligible for an exemption on share sales.
Capital losses are tax-deductible.

Main Allowable Deductions and Tax Credits

Costs incurred for the purposes of deriving, securing or preserving a source of revenue are generally deductible.
Accrued interest on loans and credit that were paid or capitalised are deductible for corporate income tax purposes. Creditors may reduce their tax base by the value of receivables if monetary payment has not been paid or sold after 90 days from the invoice due date.
Companies are entitled to deduct donations for the purposes of public benefit and to volunteer activity organisations up to a total amount not exceeding 10% of income.

Deductions may be claimed for royalties, management services, and interest charges paid to foreign affiliates. Taxes can generally be deducted (except for CIT, industry-specific taxes and VAT). Certain fines and penalties can be deducted.

As a general rule, transactions with a value above PLN 15,000 can only be deducted when paid using a bank transfer.

An extra deduction, ranging from 100% to 200% of qualifying expenses for R&D activities, known as R&D relief, might be accessible. These expenses cover employee costs and other eligible expenditures if the company qualifies as an R&D center. Additionally, a deduction for costs linked to innovative employees, as a complement to R&D relief, is available. Employers unable to directly benefit from R&D relief can deduct the relief's value from income tax advance payments remitted on innovative employees’ salaries. This complementary incentive applies to employees spending at least 50% of their time in R&D activities. Small and start-up taxpayers may avail themselves of a one-time depreciation write-off of up to EUR 50,000 as de minimis aid. A notional interest deduction of up to PLN 250,000 annually is accessible under specific conditions. A reduced 5% tax rate may apply to income from selected intellectual property created, developed, or enhanced through the taxpayer’s R&D activity. Furthermore, various innovation tax reliefs are available, including prototype relief, IPO relief, robotization relief, expansion relief, and CSR relief, each offering additional deductions or incentives for specific activities or investments.

Tax losses are allowed to be carried forward for up to five consecutive tax years, with a limitation that no more than 50% of the loss amount from a specific past year can be utilized in any single subsequent tax year. Tax losses cannot be carried back to offset previous years' profits or taxes.

Other Corporate Taxes

Other taxes levied include capital duty (0.5% of the nominal value of share capital), specific intangible services paid to non-residents (20% withholding tax on services e.g. legal, accounting, advertising, market research, recruiting, guarantees), an excise tax on turnover of selected goods and tax on extraction of certain materials.

Real property tax rates are fixed by municipalities within limits set in the Law on Local Taxes and Fees. In 2024, land used for business purposes is subject to a rate of PLN 1.34 per square metre. Buildings used for business purposes are subject to a rate of PLN 33.10 per square metre (depending on local authorities). Stamp duties and a transfer tax (0.5-2% on transactions such as sales and loans that are not covered by VAT) also apply.

As far as the social security system is concerned, employer contributions range from 19.48% to 22.14% of the employee's gross salary; the contribution rate for the employee is 13.71% of the gross salary. The rates apply to salaries below PLN 234,720 (2024). Above this limit, the salary is subject to a contribution rate of 3.22% to 5.88% payable by the employer (2.45% payable by the employee). Contributions to a new type of retirement savings plan financed jointly by the employee, the employer and the government (Employee Capital Plans - PPK), are equal to 1.5% for the employer and 2% for the employee. Persons are enrolled by default but have the option to opt-out.

An additional tax is levied on the activities of certain financial institutions including local banks, branches of foreign banks, and insurance and reinsurance companies. The tax applies at a rate of 0.0366% per month when the value of assets exceeds PLN 200 million in the case of credit institutions, PLN 2 billion in the case of insurance and reinsurance companies and PLN 4 billion in the case of other financial institutions.
Shipping companies may opt to pay tonnage tax on certain types of income. A special tax is imposed on the excavation of silver, copper, crude oil, and natural gas

An income tax from retail sales applies to retailers whose monthly turnover exceeds PLN 17 million at 0.8% on revenues up to PLN 170 million and 1.4% on revenues in excess of this amount.

Other Domestic Resources

Ministry of Finance

Tax Rate

Allowable Deductions and Tax Credits

Deductions apply to items such as donations (capped at 6% of taxable income), Polish and EU national social security contributions, expenses incurred by disabled persons and some expenses incurred on technical knowledge or contributions to an Individual Pension Insurance Account. Interest is also deductible on an accrual basis. Foreign tax relief is also available; however, the amount of tax credit cannot exceed the amount of domestic tax that would have been due should the foreign income have been derived in Poland. Health insurance contributions cannot be deducted from tax liability due (it was possible up to the annual tax return for 2021).

A standard deduction applies to employees, generally at PLN 250 per month. The annual limit of tax costs from one's employment currently cannot exceed PLN 3,000.
An independent worker may claim various allowances, depending on the type of activities performed (the standard deduction usually amounts to 20% of the revenue, but can go up to 50% or PLN 120,000 for creative activities).

As of January 1, 2022, taxpayers earning income taxed according to the tax scale are entitled to a personal allowance of PLN 30,000. From the same date, a tax relief was introduced for single parents, for a deduction of PLN 1,500 per year from the personal income tax due.

The annual income tax can be further reduced by:
- PLN 1,112 per child in a family consisting of one child, provided that the taxpayers’ joint annual taxable income is not higher than PLN 112,000 (for married taxpayers) or PLN 56,000 (for single taxpayers)
- PLN 1,112 per child in a family consisting of two children (irrespective of taxpayer’s income), or
- PLN 1,112 per first and second child, PLN 2,000 per third child, and PLN 2,700 per fourth and each subsequent child in a family consisting of three or more children (irrespective of taxpayer’s income).

Individuals running business activities as sole traders or partners in partnerships can deduct all expenses incurred in order to derive revenue or to "protect a source of income", unless differently specified.

Special Expatriate Tax Regime

Residents pay personal income tax for worldwide income while non-residents pay PIT only on Polish-source income. Expatriates and natives pay the same taxes in Poland.Non-residents earning specific types of income in Poland face unique taxation rules. Typically, these earnings are taxed at a flat rate of 20%, based on revenue without allowance for cost deductions. However, exceptions may apply if a double tax treaty between Poland and the individual's country of residence dictates otherwise. The types of income subject to this treatment include:

- Revenue from intellectual property, such as copyrights, trademarks, patents, and designs (including proceeds from their sale).
- Income from technology and know-how transfers.
- Compensation for leasing industrial, commercial, or scientific equipment.
- Earnings from freelance work in various fields like art, literature, science, education, journalism, and sports (including participation in related competitions).
- Fees for services commissioned by national or local authorities, administrative bodies, courts, or prosecutors.
- Payments for membership on boards of directors, supervisory boards, committees, and similar decision-making bodies of legal entities.
- Income from providing personal services under agreements with individuals or entities, excluding those offered as part of independent business activities (i.e., not available to the public).
- Earnings from activities performed personally under management or similar contracts.