Taxes in Poland for a sp. z o.o.

Polish company taxes in 2026 at a glance

CIT at 19% and 9%: who qualifies for the lower rate

Two groups can use the 9% rate: small taxpayers, whose revenue including VAT in the previous year stayed within the equivalent of EUR 2 million, and companies in their first year of activity. In both cases revenue for the current tax year must also stay within EUR 2 million. According to the Polish Ministry of Finance, in 2026 that means PLN 8,517,000 for small taxpayer status and PLN 8,431,000 for the 9% rate itself.

Limits worth knowing in advance:

• capital gains, for example from selling shares, are always taxed at 19%;
• companies formed through certain restructurings, or by contributing an existing business, cannot use 9% in their first years;
• from 2026, for a tax year shorter or longer than 12 months, the EUR 2 million limit is prorated by the number of full months.

The annual CIT-8 return is due by the end of the third month after the tax year ends, which is 31 March for a calendar year. CIT advances are paid during the year.

Estonian CIT in Poland: tax only when profit is paid out

Estonian CIT (ryczałt od dochodów spółek) moves the tax point from earning profit to distributing it. While profit stays in the company and is reinvested, no corporate income tax is due. The rate is 10% for small and start-up taxpayers and 20% for others. The tax base covers distributed profit, hidden profit distributions (such as benefits to shareholders and related parties) and expenses unrelated to the business.

The conditions in Article 28j of the CIT Act must all be met:

• all shareholders are individuals;
• less than 50% of last year's revenue comes from passive sources: interest, receivables, leasing, guarantees, IP rights, financial instruments, or related-party transactions with little or no added value;
• the company employs at least 3 full-time staff who are not shareholders, or spends at least three times the average monthly enterprise-sector salary each month on at least three people engaged under other contracts;
• the company holds no shares in other companies and no units in investment funds;
• it notifies the tax office of its choice by the end of the first month of the year in which the regime starts.

New companies get a grace period: the passive-income test counts as met in the first year, and the employment condition does not apply in the start-up year and the two following years. From the second year, headcount has to grow by at least one full-time position a year. A small taxpayer needs only one employee in its first year under the regime.

The regime suits businesses that reinvest. If the owner plans to take out all profit every year, we calculate the combined tax at company and shareholder level and compare it with standard CIT.

VAT in Poland: rates, exemption and registration

The standard VAT rate is 23%, with reduced rates of 8% and 5% for goods and services listed in the annexes to the VAT Act. From 1 January 2026, a business established in Poland may stay outside VAT registration while its sales excluding VAT remain within PLN 240,000 a year; the previous limit was PLN 200,000.

The exemption is closed to legal and advisory services, jewellery services, debt collection and a range of goods, including excise goods, new means of transport, and electronics and cosmetics sold online, among others listed in Article 113 of the VAT Act. A company trading with EU customers or suppliers also needs a VAT-UE number on top of standard registration.

Tax residence of the company and its owner

A Polish company pays CIT on its worldwide income if its registered office (siedziba) or its management (zarząd) is in Poland. Management counts as Polish when the company's day-to-day affairs are run from Poland in an organised and continuous way, for example under contracts, powers of attorney or board resolutions.

An individual is Polish tax resident if they spend more than 183 days a year in Poland or their centre of vital interests is there. When two countries both claim a person as resident, the tie-breaker rules of the relevant tax treaty decide. Our tax residency guide explains how this works in practice and which documents to keep.

The owner's home country looks at the same facts from its side. Ukraine, for example, can treat a foreign company as Ukrainian tax resident if it is effectively managed from Ukraine. That is why we settle before registration who sits on the management board, where board meetings take place and how this is documented.

Dividends and the Poland–Ukraine tax treaty

A Polish company withholds 19% on dividends on the day of payment. For Ukrainian owners, the Poland–Ukraine treaty of 12 January 1993 caps the Polish tax:

The Polish company may apply a treaty rate only if it holds the recipient's certificate of tax residence, and it must check the conditions with due diligence. Where dividends, interest or royalties paid to a related party exceed PLN 2,000,000 in a year, the company withholds tax at the Polish rate on the excess, and the recipient reclaims the treaty reduction separately.

Owners resident in other countries follow the treaty between Poland and their own country. We model the full payment route (dividends, board member salary, loans, royalties, services) before the first payment, because it drives the tax in both countries.

CFC rules for the owner

If the owner is tax resident in a country with controlled foreign company rules, such as Ukraine, owning a Polish sp. z o.o. can trigger annual CFC reporting and, unless an exemption applies, tax on the company's adjusted profit at home. Whether an exemption applies depends on the structure, the Polish tax rate and the company's numbers, so we check it before registration. Polish bookkeeping data feeds straight into the CFC report.

Filing calendar

A sp. z o.o. must always keep full accounting books. Monthly bookkeeping is covered on our international accounting services page.

A Polish company and residence rights

Registering a sp. z o.o. gives no immigration status by itself. A residence permit for running a business is issued by the voivode under separate conditions, including the company's income for the previous year or its full-time staff. Residence questions are handled separately from tax and incorporation.

How we help

1. Review the business, shareholders, place of management and the owners' countries of residence.
2. Calculate tax in Poland and in the owner's country: standard or Estonian CIT, dividends, CFC rules, board member pay.
3. Settle VAT: whether to register from day one, VAT-UE, JPK and KSeF.
4. Register the company; the process is described on our company formation in Poland page.
5. Set up bookkeeping and annual reporting in Poland, plus CFC reporting where the owner needs it.

Related pages

• Company formation in Poland: sp. z o.o. for non-residents.
• Czech corporate tax and VAT: a comparison for s.r.o. owners.
• Registration of companies in Europe: comparing EU countries.
• Controlled foreign companies: owner-level tax and reporting.

Sources: Polish Ministry of Finance — CIT rates and limits; Estonian CIT rates and limits; VAT rates and limits; CIT Act, Journal of Laws 2026 item 554 (Arts. 3, 19, 21, 22, 24d, 26, 28j–28r); VAT Act, Journal of Laws 2026 item 1263 (Arts. 41, 99, 113, 145l, 145m, 146ef); Poland–Ukraine double tax treaty, Journal of Laws 1994 No. 63 item 269; powroty.gov.pl — tax residence; biznes.gov.pl — CIT-8; KAS — financial statement deadlines; Ministry of Finance — CRBR. Checked on 9 October 2026.