After the end of the tax year, every taxpayer has to settle the income earned with the tax office (urząd skarbowy). For legal persons and certain organisational units, the document used for this is the CIT-8 annual return. It is the key form in the CIT (corporate income tax) system and requires particular attention because of the complexity of the rules and the strict filing deadlines.
The CIT-8 return is not a universal document filed by all taxpayers. It has a very specific use and applies to strictly defined groups of business entities. Understanding who has to file it, what the taxation rules are and how the settlement procedures work is the basis for operating correctly in the tax system.
Entities required to file the CIT-8 return
The obligation to file the CIT-8 annual return does not cover all taxpayers operating on the Polish market. The Corporate Income Tax Act sets out precisely which entities must use this form for their annual tax settlement.
Legal persons are the main group of taxpayers required to file the CIT-8. They include sp. z o.o. (limited liability company), joint-stock companies (spółka akcyjna), associations and cooperatives. As a rule, they settle their tax using this return regardless of the type of activity they carry out. Exceptions include, among others, companies taxed under the lump-sum tax on company income (Estonian CIT), which file the CIT-8E return (Article 28r(1) of the CIT Act)
A special category consists of capital companies in organisation, i.e. companies at the stage between the conclusion of the articles of association and entry in the register of entrepreneurs. Even though they do not yet have full legal personality, they are already subject to tax at this stage and must file the CIT-8 return.
Organisational units without legal personality also fall within the scope of the CIT-8, but with an important exception. Excluded are enterprises in probate and companies without legal personality, subject to the companies listed in Article 1(3) of the Act (Article 1(2)). On the other hand, housing communities, for example, are CIT taxpayers and may benefit from an exemption for certain income (Article 17(1)(44)). This distinction is fundamental to classifying an entity correctly in terms of its tax obligations.
Limited joint-stock partnerships (spółka komandytowo-akcyjna) and limited partnerships (spółka komandytowa, since 2021) with their registered office or management in Poland are another group of CIT-8 taxpayers. General partnerships (spółka jawna) whose partners are not exclusively natural persons are also taxpayers, on a conditional basis, if they do not submit information about their partners on time (Article 1(3)(1) and (1a) of the CIT Act). These legal forms combine features of partnerships and capital companies, which means their tax settlements require particular attention
The international aspect of taxation covers companies without legal personality that have their registered office or management in another country. The key criterion here is how the tax law of that other country treats them – if they are treated as legal persons and are taxed there on their worldwide income, they also file the CIT-8 in Poland. Rates and the general corporate income tax rules in Poland are covered in a separate article.
- Limited liability companies carrying out business activity
- Joint-stock companies, both listed on the stock exchange and private
- Associations carrying out statutory and business activities
- Cooperatives of all types of activity
- Foundations pursuing statutory goals and additional activity
The legislator has also provided exemptions from the obligation to file the CIT-8 return. Under Article 27(1) of the Corporate Income Tax Act, taxpayers exempt from tax under Article 6(1) do not file the return. This category includes, among others, the State Treasury, the National Bank of Poland, budgetary units and local government units (with respect to the income specified in the Act on local government revenue).
Also exempt are, among others, international enterprises set up by a state administration body jointly with other states, unless the agreement or treaty provides otherwise (Article 6(1)(5)). Church legal persons do not file the CIT-8 with respect to income from non-business statutory activity (Article 27(1) in conjunction with Article 17(1)(4a)(a))
An important limitation concerns natural persons and persons doing business in the form of companies without legal personality. As a rule, these entities do not file the CIT-8, except for the limited joint-stock partnerships and limited partnerships with their management or registered office in Poland mentioned above, and general partnerships meeting the conditions of Article 1(3)(1a).
Taxation rules and CIT rates
The corporate income tax system is based on taxing all income earned by CIT-8 taxpayers, regardless of its source. This universal principle means that both income from operating activity and income from other sources are taxed.
The tax base is the excess of revenue over the tax-deductible costs of earning it in a given tax year. This approach requires a precise distinction between revenue and costs, which is often a challenge for taxpayers with complex business activities.
In some cases dividends (Article 22(1) of the CIT Act, with a possible exemption under Article 22(4)) and interest received on receivables are also taxed – interest that has been charged but not received is not revenue (Article 12(4)(2)). These additional elements of the tax base can significantly affect the final amount of the tax liability
The current system provides for two basic CIT rates, which apply depending on the category of taxpayer and the type of income earned (since 2026 banks and credit unions (SKOK) have separate rates – Article 19(1)(3)–(5)). This dual rate structure is part of a tax policy supporting the development of small and medium-sized enterprises.
The 19% rate is the basic tax rate applied to income earned under the general rules. It also covers income from dividends and other revenue from a share in the profits of legal persons with their registered office or management in the Republic of Poland. This rate also applies to the foreign income of companies with their registered office or management in Poland.
The 9% rate was introduced as a preference for small taxpayers and entities starting a business. It applies to income other than from the capital gains listed in Article 7b(1) of the CIT Act, provided that revenue in the tax year does not exceed the equivalent of EUR 2,000,000 (converted at the NBP exchange rate from the first business day of the tax year) – Article 19(1)(2)
The reduced 9% rate is particularly important for the development of entrepreneurship in Poland. Its use is limited to certain categories of taxpayers and does not cover all types of income. The exclusion of capital gains income means that this income is always taxed at the basic rate of 19%.
Qualifying for the right tax rate requires a detailed analysis of the taxpayer's legal and financial situation. The 9% rate is applied by a taxpayer with small taxpayer status (sales revenue including VAT for the previous year up to the equivalent of EUR 2,000,000 – in 2026 PLN 8,517,000; Article 4a(10)), and this condition does not apply in the year a business starts (Article 19(1d)–(1e)). The preference is not available to, among others, tax capital groups and family foundations, nor to taxpayers formed, for example, through a transformation or the contribution of an enterprise – in the year of formation and the following year (Article 19(1a)–(1b)).
Settling tax advances and how tax is paid
The CIT payment system is based on periodic tax advances paid during the tax year. This ensures a steady flow of revenue to the state budget and spreads the taxpayer's financial burden over time.
Advances on income tax are paid monthly or quarterly, depending on the size of the taxpayer and its own choices. The payment deadline is the 20th day of the month immediately following the end of the given settlement period. For clients of our accounting services, we calculate CIT advances and keep track of their deadlines.
The CIT-8 return is used to reconcile the tax paid during the year with the tax actually due. Comparing these amounts determines whether the taxpayer has an additional amount to pay or can expect a refund of an overpayment
Settlement in the CIT-8 return involves calculating the tax on the basis of the annual statement of income and costs and then reducing it by all advances paid during the tax year. The difference between these amounts is the final liability or the overpayment to be settled with the tax office.
The legislator has provided a de minimis threshold for tax liabilities. Where the tax due on income since the beginning of the year, after deducting the advances already paid, does not exceed PLN 1,000, the taxpayer may refrain from paying the advance. This simplifies procedures for taxpayers with small liabilities.
If the tax due on income earned since the beginning of the year, less the total advances paid, exceeds PLN 1,000, the whole of that difference must be paid (Article 25(18) of the CIT Act). This means that the PLN 1,000 threshold is not deducted from each advance but is calculated cumulatively from the beginning of the year
This mechanism aims to reduce administrative costs for both taxpayers and the tax administration. It avoids situations in which the cost of handling small liabilities would exceed their value.
- Calculate the taxable income for the whole tax year
- Apply the appropriate tax rate (9% or 19%)
- Add up all advances paid during the year
- Deduct the advances paid from the annual tax calculated
- Determine the final liability or overpayment to be settled
The tax year and how it is set for CIT-8 purposes
Determining the tax year is fundamental to settling CIT correctly and filing the return on time. Polish tax law gives taxpayers some flexibility here, which can be used to optimise accounting and tax processes.
Under Article 8(1) of the Corporate Income Tax Act, the tax year is the calendar year, unless the taxpayer decides otherwise in its statute, articles of association or another document governing its constitutional rules. In that case, the tax year may be a period of twelve consecutive calendar months.
A taxpayer required to file the CIT-8 may decide for itself which tax year it will settle for. This choice makes it possible to adapt the settlement cycle to the nature of the business
Special rules apply to taxpayers starting a business for the first time. The first tax year runs from the day the business starts until the end of the given calendar year or the last day of the chosen tax year, but not longer than twelve consecutive calendar months.
An additional rule in Article 8(2a) of the Act covers the situation where a taxpayer starts a business in the second half of the calendar year and chooses a tax year that coincides with the calendar year. In that case, the first tax year may run from the day the business starts until the end of the calendar year following the year in which the business started.
Company X started its business on 10 November 2023 and stated in its articles of association that its tax year would be the calendar year. Because it started in the second half of the year, its first tax year could last 14 months – from 10 November 2023 to 31 December 2024. This extension is intended to avoid a very short first settlement period.
Taxpayers starting a business for the first time report the choice of a tax year other than the calendar year in the annual return filed for the year in which they obtained taxpayer status (Article 8(5)). The choice itself is made in the statute, the articles of association or another constitutional document (Article 8(1))
The rules also allow the tax year to be changed while the business is running. The first new tax year after the change is the period from the beginning of the month following the end of the previous tax year until the end of the newly adopted tax year.
An important limitation concerns the length of the transitional period when the tax year is changed. Under Article 8(3) of the Corporate Income Tax Act, this period may not be shorter than 12 or longer than 23 consecutive calendar months.
- Calendar year from January to December
- Business year adapted to the business cycle
- Financial year set in the articles of association or statute
- Fiscal year aligned with the company's budget
- Operating year reflecting the seasonality of the business
The change of tax year must be reported in the annual return filed for the tax year preceding the first year after the change. This procedural requirement ensures continuity of tax supervision and correct identification of settlement periods.
Company A, a limited joint-stock partnership, had settled tax on a calendar-year basis since 2015. In the return filed on 15 January 2023, it reported a change of its tax year to a June-to-May period. The first tax year after the change was the period from 1 January 2023 to 31 May 2024, covering 17 months.
Companies forming a tax capital group must have the same tax year. This requirement ensures consistency of consolidated settlements and limits complications in settling intra-group transactions
Deadlines and procedures for filing the CIT-8 return
Filing the CIT-8 return correctly requires compliance with strictly defined deadlines and procedures, which are clearly set out in the Corporate Income Tax Act. Failure to comply with these requirements can lead to serious financial and legal consequences.
The basic deadline for filing the CIT-8 return is 3 months from the end of the tax year for which the return is filed. The deadline follows directly from the Act (Article 27(1): by the end of the third month of the following year) and does not require a summons from the tax office, which means that taxpayers must prepare all the necessary documents and calculations well in advance.
The CIT-8 return is filed by electronic means of communication (Article 27(1c) of the CIT Act). Article 27a allows a paper return only for taxpayers earning exclusively income exempt from tax under Article 17(1) who do not file certain other returns and information
Apart from this exception, the return cannot be filed on paper. In practice, a company's return is most often signed with a qualified electronic signature, which confirms the authenticity of the document and its integrity during transmission to the tax system.
As a rule, the tax office competent for the return is determined on the basis of the taxpayer's registered office address (Article 17 § 1 of the Tax Ordinance Act (Ordynacja podatkowa)). The registered office is established according to the KRS (National Court Register), the statute or the articles of association, and if the registered office changes during the tax year, the office that was competent on the first day of the tax year remains competent for that year (Article 18 § 1 of the Tax Ordinance Act).
| Type of entity | Basis for determining competence | Reference documents | Special notes |
|---|---|---|---|
| Capital companies | Entry in the KRS | Register of entrepreneurs | Registered office on the first day of the tax year |
| Companies in organisation | Articles of association | Notarial deed or agreement concluded in the S24 system | Before entry in the KRS |
| Organisational units | Statute or regulations | Founding documents | Actual registered office |
| Foreign branches | Business registration | Business register | Specialised offices |
Special rules apply to entities with larger operations or of a specific legal nature. Branches and representative offices of foreign entrepreneurs, tax capital groups and the companies in them, banks, insurance companies, public companies, and legal persons and organisational units without legal personality (except civil-law partnerships) with net sales revenue of at least EUR 3 million file their returns with specialised tax offices.
Detailed rules on the competent office for large taxpayers are set out in the regulation of the Minister of Finance, Funds and Regional Policy of 28 December 2020 on certain taxpayers and payers for whom tasks are performed by the head of a tax office other than the locally competent one (Dz.U. (Journal of Laws) 2020, item 2456, amended by Dz.U. 2025, item 1145). These rules ensure an appropriate level of specialisation of the officials handling complex tax cases
The obligation to file the CIT-8 return arises regardless of whether the taxpayer made a profit or a loss in the given tax year. Where there is no tax to pay, taxpayers file a so-called "nil" CIT-8, which documents the absence of a tax liability but confirms that the reporting obligation has been met.
A company operating on a July-to-June tax year filed its return for the year ending 30 June 2024. The deadline for filing the CIT-8 return falls on 30 September 2024, i.e. exactly 3 months after the end of the tax year.
The tax liability arising from the CIT-8 is paid by bank transfer to the individual tax micro-account (mikrorachunek podatkowy, Article 61b of the Tax Ordinance Act). Payment must be made by the same deadline as the return, i.e. within 3 months of the end of the tax year.
When making the payment, you must state the entity and the subject of the payment, giving the CIT-8 symbol and the tax year to which the settlement relates. A correctly described transfer ensures that the payment is properly allocated in the tax system
- Prepare all accounting documents for the whole tax year
- Calculate taxable income under the CIT rules
- Complete the CIT-8 form in the electronic system
- Sign the return electronically (most often with a qualified electronic signature)
- File the return with the competent tax office within 3 months
- Pay the tax liability arising from the return
- Keep the confirmations of filing the return and making the payment
