• private limited companies, public limited companies and other legal persons (e.g. foundations, associations and cooperatives);
• capital companies in organisation;
• partnerships limited by shares having their registered office or place of management in Poland;
• companies without legal personality having their registered office or place of management in another country, if they are regarded as legal persons in accordance with the tax law of that country and their entire income is subject to taxation in that country, regardless of where this income was earned;
• organisational units without legal personality (e.g. housing cooperatives, educational establishments), with the exception of civil-law partnerships, ordinary partnerships, professional partnerships and limited partnerships;
• tax capital groups (groups consisting of at least two commercial companies having legal personality, registered in the revenue office, which are related by capital and meet specific conditions).

Partnerships, with the exception of partnerships limited by shares, are not taxable persons for CIT purposes. Taxable persons for CIT purposes are indirectly their partners, and these partners’ shares in the companies are subject to taxation.

• the State Treasury,
• the National Bank of Poland (Narodowy Bank Polski),
• budgetary units,
• state special-purpose funds,
• local government units, with regard to income specified in the Act on incomes of local government units,
• open-end funds,
• pension funds,
• the Social Insurance Institution (Zakład Ubezpieczeń Społecznych),
• the National Health Fund (Narodowy Fundusz Zdrowia).

Taxpayers whose registered office or place of management is in Poland pay tax on their entire income in Poland, regardless of where this income was earned (unlimited tax liability).

Taxpayers whose registered office or place of management is not located in Poland pay tax only on the income earned in Poland (limited tax liability).

You will pay CIT if you have earned incomes (revenues) in Poland from, inter alia:

• business activity run in Poland, including through a foreign establishment located in Poland,
• the rental or lease of real estate located in Poland, or from the sale of this real estate,
• securities or derivative financial instruments,
• the disposal of shares in a capital company, and the entirety of rights and obligations in a company which is not a legal person or participation units in investment funds.

Taxable persons for corporate income tax purposes in Poland are subject to the registration requirement. In such a case, you must obtain a tax identification number (NIP). In order to obtain a NIP, you must submit an identification application.

You only need to submit it once, regardless of:

• the type and number of taxes paid,
• the form of taxation,
• the number and types of your economic activities and undertakings.

If you are subject to pay tax on goods and services (VAT) or excise duty, you must submit your identification application before your business carries out its first transaction subject to one of these taxes. The identification application is submitted independently of your registration application.

If you are not registered as a taxable person for VAT purposes, you must submit your identification application before the deadline for submission of your first declaration, return, information or statement, or upon your first tax payment or prepayment.

If you are registered with the National Court Register as a taxable person, you must submit an identification application regarding supplementary data within 21 days of being entered in the National Court Register.

If the current tax law provides for different deadlines for submitting an identification application, you must submit it once at the earliest designated date.

The subject of taxation is the sum of incomes from all sources of revenue (capital gains and others).

In special cases, the subject of taxation may be revenue (e.g. from dividends).

In the case of CIT, sources of revenue include:

• capital gains – including dividends, other revenues actually obtained from participation in profits of legal persons and partnerships limited by shares, the value of assets obtained following the liquidation of a legal person or a partnership limited by shares, revenues from the disposal of shares in companies, revenues from the disposal of receivables previously purchased by the taxable person, revenues from property rights such as copyrights or related property rights, licences, trademarks and know-how, revenues from securities and derivative financial instruments, and revenues from the disposal of the entirety of rights and obligations in a partnership;
• other revenues – including revenues from the sale of goods and assets and the supply of services, etc.

The basic CIT rates are as follows:

• 19% of the tax base,
• 9% of the tax base.

You may benefit from the reduced tax rate of 9% if you:

• start business activity and the revenues in the fiscal year in which you applied the reduced tax rate did not exceed the PLN equivalent of EUR 1 200 000;
• continue to run business activity and meet the following two revenue-related criteria:
  • you are a small taxpayer – gross sales revenues (together with due VAT) in the previous fiscal year did not exceed the PLN equivalent of EUR 2 000 000, and
  • your revenues in the fiscal year in which you applied the reduced rate did not exceed the PLN equivalent of EUR 1 200 000.

In certain cases involving conversions and contributions in kind, the 9% tax rate cannot be applied.

1. You will pay tax on revenues from buildings if you own or co-own a building located in Poland and you rent/lease that building for use under a rent/lease agreement or another similar agreement.

   The tax rate is 0.035% of the sum of initial values of all buildings, reduced PLN 10 000 000 per month.

2. You will pay tax on income from shares in controlled foreign companies (CFCs) if you have the status of a resident in Poland and earn income from the activities carried out by these corporations.

   The tax rate is 19% of the taxable amount.

3. The rate of tax on incomes from qualified intellectual property rights -IP Box (upon meeting statutory requirements) is 5% of the taxable base.

   You will pay the reduced 5% tax rate from incomes derived from qualified intellectual property rights (IP Box) created, developed or improved by the taxpayer as a part of his R&D activity.

   Qualified intellectual property rights include:

   1. patents,
   2. protection rights for utility models,
   3. rights from registration of industrial designs,
   4. rights from registration of topographies of semiconductor products,
   5. additional protection rights for patents for medicinal products or plant protection products,
   6. rights from registration of authorised medicinal products and veterinary medicinal products,
   7. the exclusive right referred to in the Act on legal protection of plant varieties,
   8. copyrights of computer programs.

4. You will pay tax on income from unrealised profits (exit tax) if you:

   1. transfer an asset outside Poland, as a result of which Poland loses, in whole or in part, the right to tax income from the disposal of this asset,
   2. change tax residency, as a result of which Poland loses, in whole or in part, the right to tax income from the disposal of an asset that you own in connection with the transfer of your registered office or place of management to another country.

   The tax rate is 19% of the taxable base.

5. Tax on dividends received and other revenues (incomes) from participation in profits of legal persons having their registered office or place of management in Poland concerns, inter alia, revenues (incomes) from dividends, other revenues actually obtained from participation in profits of legal persons and partnerships limited by shares, the value of assets obtained following the liquidation of a legal person or a partnership limited by shares, and revenues obtained as a result of conversions, mergers or divisions of entities.

   The tax rate is 19% of the taxable amount.

6. If you have the status of a non-resident (you do not have your registered office or place of management in Poland), the rate of the tax on revenues earned in Poland is as follows:

   1. 20% for revenues from, inter alia:

      • interest, copyrights or related rights, and the use of or the right to use industrial equipment, including means of transport, commercial or scientific equipment, and information related to experience gained in the field of industry, commerce or science (know-how),
      • fees for services provided in the field of performing arts, entertainment or sports,
      • advisory services, accounting services, market research services, legal services, advertising services, management and control services, data processing services, the recruitment of employees and acquisition of personnel, the provision of guarantees and sureties, and similar services;

   2. 10% for revenues from, inter alia:

      • charges for the export of goods and passengers by foreign maritime shipping companies,
      • services provided by foreign air shipping companies.

In certain cases, you do not have to pay the tax in Poland or you may pay it at the reduced rate. Please read the relevant double taxation agreement to find out where to pay CIT and what amount of tax to pay.

You submit the CIT-8 and CIT-8AB tax returns in electronic form, signed with a qualified electronic signature.

The CIT-CFC and CIT-NZ declarations are submitted in electronic or paper form.

The electronic forms can be found at www.podatki.gov.pl.

Important: an Official Confirmation of Receipt is used to confirm that a declaration in electronic form has been received. Please remember to check if you have received one.

If you do not wish to submit a tax return in person, your attorney may do it for you.

The fiscal year for CIT purposes is the calendar year (from 1 January to 31 December). You may, however, determine a fiscal year that will not coincide with the calendar year by yourself. The fiscal year should then be a period of 12 consecutive months. You may change the fiscal year adopted.

During the fiscal year, you are required to pay the income tax withheld to the revenue office. You may pay the amounts withheld:

• monthly – by the 20th day of each month for the previous month
• quarterly – by the 20th day of the month following the end of a quarter (small taxpayers, taxable persons setting up businesses)

You do not submit tax returns during the fiscal year.

After the end of the fiscal year, you submit an annual tax return for income earned or losses sustained to the revenue office (CIT-8).

You should do this by the end of the third month of the year following the fiscal year. By this deadline, you are also required to pay the tax due or the difference between the tax due on the income declared in the tax return and the sum of amounts withheld due since the beginning of the year.

Please note: You should submit the CIT-8AB tax return if you are a parent company in a tax capital group.

You declare income from activities carried out by controlled foreign corporations in the CIT-CFC tax return. You do it separately for each corporation.

You should submit the tax returns by the end of the ninth month of the year following the fiscal year. By this deadline, you are also required to pay the tax due.

If you earn income from unrealised profits, you should submit the CIT-NZ declaration.

You should do this by the seventh day of the month following the month in which the income from unrealised profits was generated. By this deadline, you are also required to pay the tax due.

The basic CIT rates are as follows:

• 19% of the tax base,
• 9% of the tax base.

You may benefit from the reduced tax rate of 9% if you:

• start  business activity and the revenues in the fiscal year in which you applied the reduced tax rate did not exceed the PLN equivalent of EUR 1 200 000;
• continue to run  business activity and meet the following two revenue-related criteria:

• you are a small taxpayer – gross sales revenues (together with due VAT) in the previous fiscal year did not exceed the PLN equivalent of EUR 2 000 000, and
• your revenues in the fiscal year in which you applied the reduced rate did not exceed the PLN equivalent of EUR 1 200 000.

In certain cases involving conversions and contributions in kind, the 9% tax rate cannot be applied.

1. You will pay tax on revenues from buildings if you own or co-own a building located in Poland and you rent/lease that building for use under a rent/lease agreement or another similar agreement.
   The tax rate is 0.035% of the sum of initial values of all buildings, reduced PLN 10 000 000 per month.
2. You will pay tax on income from shares in controlled foreign companies (CFCs) if you have the status of a resident in Poland and earn income from the activities carried out by these corporations.
   The tax rate is 19% of the taxable amount.
   The rate of tax on incomes from qualified intellectual property rights -IP Box (upon meeting statutory requirements) is 5% of the taxable base.

You will pay the reduced 5% tax rate from incomes derived from qualified intellectual property rights (IP Box) created, developed or improved by the taxpayer as a part of his R&D activity.

Qualified intellectual property rights include:

1. patents,
2. protection rights for utility models,
3. rights from registration of industrial designs,
4. rights from registration of topographies of semiconductor products,
5. additional protection rights for patents for medicinal products or plant protection products,
6. rights from registration of authorised medicinal products and veterinary medicinal products,
7. the exclusive right referred to in the Act on legal protection of plant varieties,
8. copyrights of computer programs.

You will pay tax on income from unrealised profits (exit tax) if you:

1. transfer an asset outside Poland, as a result of which Poland loses, in whole or in part, the right to tax income from the disposal of this asset,
2. change tax residency, as a result of which Poland loses, in whole or in part, the right to tax income from the disposal of an asset that you own in connection with the transfer of your registered office or place of management to another country.

The tax rate is 19% of the taxable base.

1. Tax on dividends received and other revenues (incomes) from participation in profits of legal persons having their registered office or place of management in Poland concerns, inter alia, revenues (incomes) from dividends, other revenues actually obtained from participation in profits of legal persons and partnerships limited by shares, the value of assets obtained following the liquidation of a legal person or a partnership limited by shares, and revenues obtained as a result of conversions, mergers or divisions of entities.

The tax rate is 19% of the taxable amount.

1. If you have the status of a non-resident (you do not have your registered office or place of management in Poland), the rate of the tax on revenues earned in Poland is as follows:
   1. 20% for revenues from, inter alia:
      • interest, copyrights or related rights, and the use of or the right to use industrial equipment, including means of transport, commercial or scientific equipment, and information related to experience gained in the field of industry, commerce or science (know-how),
      • fees for services provided in the field of performing arts, entertainment or sports,
      • advisory services, accounting services, market research services, legal services, advertising services, management and control services, data processing services, the recruitment of employees and acquisition of personnel, the provision of guarantees and sureties, and similar services;
   2. 10% for revenues from, inter alia:
      • charges for the export of goods and passengers by foreign maritime shipping companies,
      • services provided by foreign air shipping companies.

In certain cases, you do not have to pay the tax in Poland or you may pay it at the reduced rate. Please read the relevant double taxation agreement to find out where to pay CIT and what amount of tax to pay.

CIT-exempt revenue includes:

• revenue from agricultural activities, except that earned from special areas of agricultural production,
• revenue from forest management,
• revenue from activities which may not be subject to a legally binding agreement,
• revenue earned by shipping entrepreneurs subject to pay tonnage tax,
• revenue earned by shipbuilding entrepreneurs subject to pay flat-rate tax.

Certain types of body also qualify for a CIT exemption and may benefit from a 'subject-based exemption' [zwolnienie podmiotowe].

The entities exempt from CIT include:

• the State Treasury,
• the National Bank of Poland (Narodowy Bank Polski),
• budgetary units,
• state special-purpose funds,
• local government units, with regard to income specified in the Act on incomes of local government units,
• open-end funds,
• pension funds,
• the Social Insurance Institution (Zakład Ubezpieczeń Społecznych),
• the National Health Fund (Narodowy Fundusz Zdrowia).

Another type of exemption is 'object-based exemption' [zwolnienie przedmiotowe], which can be divided into unconditional and conditional.

You qualify for an unconditional exemption if your source of income is exempt from income tax, regardless of your spending objectives.

Unconditional exemptions include:

• income from the sale – after 5 years (from the end of the calendar year in which the property is purchased) – of all or a part of a property or a share in a property being a part of an agricultural holding,
• income earned by church legal persons from non-economic statutory activities,
• income from economic activities carried out within a special economic zone on the basis of an appropriate authorisation,
• income from economic activities defined in the decision on support referred to in the Act on supporting new investments,
• income from raffles and bingo games with raffles,
• income earned (on a reciprocal basis) by cultural institutions from foreign countries from their economic activity on the territory of the Republic of Poland,
• grants from the state budget or financed by local government authorities,
• amounts received from government or executive agencies, if these agencies have received funds for this purpose from the state budget,
• direct payments under the Common Agricultural Policy of the European Union,
• funds received by a project participant as aid granted under a programme co-financed by EU funds,
• interest or a discount received by taxable persons whose registered office or head office is not established in Poland:
  • on bonds issued by the State Treasury and offered on foreign markets, and income from the sale of these bonds,
  • on covered bonds,
  • paid by the National Bank of Poland in connection with operations involving financial instruments that are carried out as part of foreign exchange reserve management activities,
• certain types of income (revenue) earned by closed-end or specialised open-end investment funds that operate in accordance with the investment rules and restrictions for closed-end investment funds.

Conditional exemption – all or part of your income will be exempt from taxation, but only if you use it for the purposes specified by the legislator.

Conditional exemptions include:

• income earned by taxable persons whose statutory objective is to carry out scientific, scientific and technical and educational activities, including educating students, cultural activities, activities involving physical education and sport, environmental protection, supporting social initiatives for the construction of roads and telecommunications networks in rural areas and providing water supply to rural areas, charity work, health care and social assistance, vocational and social rehabilitation of disabled persons, and religious worship – insofar as it is intended for these purposes,
• income earned by organisational bodies of the Volunteer Fire Brigade – insofar as it is intended for statutory purposes,
• income earned by public benefit organisations – insofar as it is intended for statutory activities,
• income earned by trade unions, socio-professional groups of farmers, chambers of agriculture, chambers of commerce, self-regulatory organisations of craftsmen, cooperative auditing associations, employers’ organisations, political parties, European political parties and European political foundations – insofar as it is intended for statutory purposes,
• income earned by country housewives clubs – insofar as it is intended for statutory purposes,

• income from running schools – insofar as it is used to meet certain school objectives,
• income from housing stock management – earned by housing cooperatives, housing communities, housing associations and local government authorities that are engaged in housing activities – insofar as it is used to maintain the housing stock.

You are not eligible for these exemptions if:

• your income from an economic activity which involves the manufacture of products in the field of electronics, fuel, tobacco, spirits, wine or beer, and other alcoholic products with an alcohol content over 1.5%, and articles made of or using precious metals, or income from trading in these products – is used for the stated purposes,
• your income from leasing activities is used for the stated purposes,
• your income is used for purposes other than those set out