Corporate income tax, commonly called CIT (corporate income tax), is one of the most important elements of the Polish tax system. Businesses that are legal persons must settle this tax with the tax office (urząd skarbowy), and its rates vary depending on the type of activity, the level of revenue and the available tax preferences.
Under the general rules, the object of income tax is income, regardless of the type of source from which it was earned. Income is the excess of the sum of revenue over the costs of obtaining it, earned in the tax year. If tax-deductible costs exceed total revenue, the difference is a tax loss.
CIT rates are set mainly in Chapter 5 (Articles 19–24f) and Chapter 6b (Estonian CIT, Articles 28c–28t) of the Corporate Income Tax Act (consolidated text: Journal of Laws (Dz.U.) 2026, item 554). The rates of this tax depend on the type of revenue earned, its source and the available tax preferences. Businesses can choose different forms of taxation, including Estonian CIT
What CIT is and who is subject to it
CIT is the income tax on legal persons and is the counterpart of personal income tax (PIT). The rules on its rates are set out in detail in the Corporate Income Tax Act, in particular in Chapters 5 and 6b.
Taxpayers should remember that CIT rates depend on many factors, including the type of revenue earned, its source and the available tax preferences. One of the most important preferences is the option of Estonian CIT, which can significantly affect a company's tax burden.
CIT taxpayers are legal persons, including limited liability companies (sp. z o.o.), joint-stock companies, foundations, associations and cooperatives. This group also includes capital companies in organisation and organisational units without legal personality (Article 1(1)–(2) of the CIT Act)
The list of CIT taxpayers covers a wide range of business and organisational entities. Apart from standard legal persons, taxpayers also include capital companies in organisation which have not yet acquired legal personality but already conduct business.
CIT taxpayers also include organisational units without legal personality, such as housing communities or educational institutions. The exception is partnerships without legal personality, which are usually subject to other forms of taxation.
General partnerships (spółki jawne) with their registered office or management in Poland form a special group, but only in certain cases. A general partnership is subject to CIT if its partners are not exclusively natural persons and the partnership does not file, before the start of the financial year, the required information on its CIT and PIT taxpayers entitled to a share in its profit.
Limited joint-stock partnerships (spółki komandytowo-akcyjne) and limited partnerships (spółki komandytowe) with their registered office or management in Poland are also subject to CIT. This group also includes tax capital groups registered with the tax office
Tax capital groups are a special form of taxation in which the group consists of at least two commercial companies with legal personality. These companies must be linked by capital and meet specific legal conditions to be able to settle tax in this form.
The last group of CIT taxpayers are companies without legal personality that have their registered office or management in another country. The condition is that, under that country's tax law, they are treated as legal persons and are taxed there on their worldwide income, regardless of where it is earned.
Standard CIT rates in 2026
The standard corporate income tax rate in 2026 is 19% (Article 19(1)(1) of the CIT Act) and applies to taxation under the general rules. This rate applies to most CIT taxpayers who do not meet the conditions for preferential forms of taxation. Since 1 January 2026, banks have paid CIT at higher rates: 30% in 2026, 26% in 2027 and ultimately 23%; cooperative banks and SKOKs (credit unions) pay 27%, 23% and ultimately 21% (Article 19(1)(3)–(4) and Articles 38aa–38ab of the CIT Act, introduced by the Act of 6 November 2025, Dz.U. 2025, item 1658; the years refer to taxpayers whose tax year is the calendar year).
A significant relief for smaller businesses is the reduced 9% rate (Article 19(1)(2)). This preference applies to income other than capital gains of taxpayers whose revenue earned in the tax year did not exceed the amount equivalent to EUR 2,000,000, converted at the average euro exchange rate published by the NBP (National Bank of Poland) for the first business day of the tax year, rounded to PLN 1,000. In 2026 (rate of 2 January 2026 – PLN 4.2156), this limit is PLN 8,431,000.
The 9% rate is applied by a taxpayer who at the same time has small taxpayer status (revenue from sales including VAT in the previous tax year of up to EUR 2,000,000 – PLN 8,517,000 in 2026 and PLN 8,754,000 in 2027) or is starting business – in the year it starts (Article 19(1d)–(1e)). The exceptions are the taxpayers listed in Article 19(1a)-(1c) of the Act (including those created as a result of restructuring, the transformation of a JDG (sole proprietorship) or the contribution of a business), tax capital groups and family foundations
The standard 19% rate also applies to dividends and other revenue from a share in the profits of legal persons with their registered office or management in Poland (Article 22(1); if the conditions of Article 22(4) are met, the dividend is exempt). The same rate applies to income of a controlled foreign entity earned by a taxpayer with its registered office or management in Poland (Article 24a).
The 19% rate also applies to income from unrealised gains (Article 24f) and to income from the paid disposal of virtual currencies. Income from virtual currencies counts as capital gains, so it does not qualify for the 9% rate.
Companies that in the tax year incurred a loss from sources of revenue other than capital gains, or whose share of income in revenue was no more than 2%, have been paying the minimum income tax since 2024 – 10% of the tax base, which as a rule is 1.5% of revenue (Article 24ca(1) and (3)). This does not apply, among others, to small taxpayers, taxpayers in the year they start business and in the following two years, and taxpayers whose revenue fell by at least 30% compared with the previous year (Article 24ca(14)).
- Check your revenue from sales (including VAT) in the previous tax year – this determines small taxpayer status
- Compare it with the EUR 2,000,000 limit converted into złoty
- Check that your revenue in the current tax year will not exceed the EUR 2,000,000 limit (PLN 8,431,000 in 2026)
- Choose the right tax rate for your company
- Plan your tax strategy for the following year
A special category is the income of a real estate company whose shares, stock, all rights and obligations, participation units or similar rights are sold. In such cases the 19% rate also applies.
Preferential CIT rates
The most attractive preferential rate is 5%, applied to a taxpayer's qualified income from qualified intellectual property rights. This rate, known as IP Box, is a significant incentive for companies investing in research and development and creating valuable intellectual property rights.
The 5% rate under IP Box (Article 24d of the CIT Act) applies to income from qualified intellectual property rights, including a patent, a utility model protection right, an industrial design registration right and the copyright to a computer program, created, developed or improved by the taxpayer as part of its research and development activity. To use this preference, the taxpayer must meet specific conditions relating to the nature of its activity and the type of income earned
Preferential rates are intended to support certain types of business activity, especially those related to innovation and technological development. Companies conducting research and development and generating income from intellectual property rights can significantly reduce their tax burden.
The conditions for using preferential rates are set out in detail in the Corporate Income Tax Act. Taxpayers must meet strict criteria relating to the nature of their activity and the documentation of the sources of their income.
Preferential rates are part of the state's tax policy aimed at supporting the competitiveness of the Polish economy. Supporting high-tech sectors and innovative activity, which can contribute to long-term economic growth, is particularly important.
Taxation of foreign entities
Entities that do not have their registered office or management in Poland are subject to a different tax regime. Income tax on revenue earned in Poland works differently than for domestic entities.
The standard 20% rate (Article 21(1)(1)–(2a) of the CIT Act, the so-called withholding tax) applies to a wide range of revenue earned by foreign entities. This covers interest, copyright or related rights, rights to inventions, trademarks and ornamental designs, including the sale of those rights.
The 20% rate for foreign entities also applies to fees for making available a secret formula or production process. It also covers fees for the use of industrial equipment, including means of transport, commercial or scientific equipment
| Rate | Type of revenue | Detailed application |
|---|---|---|
| 20% | Interest and copyright | Related rights, inventions, trademarks |
| 20% | Artistic services | Entertainment, recreational and sports activity |
| 20% | Advisory services | Accounting, market research, legal and advertising services |
| 10% | Sea transport | Fees for carrying cargo and passengers from Polish ports |
| 10% | Air transport | Income of foreign airlines |
The 20% rate also applies to information on experience gained in industry, trade or science, commonly known as know-how. This category of revenue is particularly important in technology transfer and international cooperation.
Revenue subject to the 20% rate also includes fees for services in the field of entertainment, recreational or sports activity. This applies to activity performed by legal persons based abroad and organised through natural or legal persons operating in this field in Poland.
The 20% rate applies to advisory, accounting, market research, legal, advertising, management and control services. It also covers data processing, recruitment services, guarantees and sureties and services of a similar nature
The lower 10% rate applies in two specific cases. The first concerns fees due for carrying cargo and passengers taken on board in Polish ports by foreign sea shipping companies, except for transit cargo and passengers.
The second case where the 10% rate applies concerns revenue earned in Poland by foreign air transport companies, excluding revenue from scheduled passenger air transport that requires the passenger to hold an air ticket (Article 21(1)(4)).
It is important to note that, when paying CIT, the rate for a given source of revenue may be modified by the relevant double tax treaty (Article 21(2) and Article 22a). These treaties may provide for lower rates or additional exemptions, which requires an individual analysis in each case.
Estonian CIT – flat-rate tax on company income
Estonian CIT, officially called the flat-rate tax on the income of capital companies (ryczałt od dochodów spółek kapitałowych), is an alternative form of taxation available to certain taxpayers. Its key feature is that taxation is deferred until profit is paid out of the company.
The basic Estonian CIT rates vary depending on the size and characteristics of the taxpayer. For a small taxpayer and a taxpayer starting business, the rate is 10% (Article 28o(1)(1) of the CIT Act).
Estonian CIT provides for a 10% rate for small taxpayers and taxpayers starting business and a 20% rate for other taxpayers (Article 28o(1)). Small taxpayer status is determined on the basis of revenue from sales in the previous tax year
For other taxpayers, the rate is 20% (Article 28o(1)(2)). This higher rate applies to larger businesses that do not meet the small taxpayer criteria or have exceeded certain revenue thresholds.
Estonian CIT is an innovative tax solution that allows profits to be reinvested without an immediate tax burden. Tax is paid only when a dividend or other form of profit distribution is paid to the shareholders. The flat-rate tax can be used by an sp. z o.o., a simple joint-stock company, a joint-stock company, a limited partnership or a limited joint-stock partnership whose shareholders or partners are exclusively natural persons, and which, among other things, employs at least 3 people who are not shareholders (under an employment contract or – with sufficiently high pay – under other contracts), does not earn 50% or more of its revenue from so-called passive sources, does not hold shares in other companies and notifies the tax office by the end of the first month of the tax year (Article 28j(1)). A special category of taxable income under this regime is income from undisclosed business operations.
This system can be particularly attractive for companies planning long-term investment and business growth. It allows effective cash flow management and spreads the tax burden over time.
- Estonian CIT defers taxation until profit is paid out
- The 10% rate applies to small taxpayers
- The 20% rate applies to other taxpayers
- The system supports reinvesting profits in business growth
- It requires certain legal conditions to be met
Choosing Estonian CIT requires a detailed analysis of the company's financial situation and growth plans. This decision has long-term consequences and should be made after consulting a tax adviser.
CIT exemptions and reliefs
The CIT system provides for various exemptions and reliefs that can significantly affect a company's final tax burden. One of the most important exemptions applies to revenue from interest, copyright and similar categories earned by foreign entities.
The exemption under Article 21(3) of the Corporate Income Tax Act covers certain revenue earned by entities without a registered office or management in Poland. This exemption can be important when planning international structures.
The CIT exemption for interest and royalties paid to companies from the European Union and the EEA is an important preference in international business. To apply it, there must be, among other things, a direct holding of at least 25% (by one company in the capital of the other) held without interruption for 2 years, and the company receiving the payments must be their beneficial owner (Article 21(3)–(4))
CIT reliefs can relate to various aspects of business activity, from investment in research and development to operations in special economic zones. Each relief has its own specific conditions and documentation requirements.
Tax planning using the available exemptions and reliefs requires in-depth knowledge of the rules and ongoing monitoring of changes in tax law. Applying a relief incorrectly can lead to serious financial consequences.
A technology company based in Warsaw carried out research and development and generated significant income from software licensing. Thanks to IP Box, it was able to use the preferential 5% rate instead of the standard 19%, which resulted in tax savings of more than PLN 500,000 a year.
Tax planning in CIT
Effective CIT planning requires a comprehensive approach to the company's organisational and financial structure. Choosing the right form of taxation can be fundamental to the company's profitability and competitiveness.
Tax thresholds and available preferences should be reviewed regularly, especially in the context of planned investments and business growth. Exceeding certain limits can mean losing the right to preferential rates.
Tax planning must take into account not only the current burden but also the long-term consequences of decisions. This is particularly important when choosing between standard CIT and Estonian CIT.
CIT planning requires taking into account all available tax preferences. Companies should consider using investment reliefs, sector exemptions and preferential rates for certain types of activity
Working with a qualified tax adviser is key to effective tax planning. The complexity of the rules and frequent changes in tax law require specialist knowledge and experience.
The tax solutions adopted should be documented transparently and completely. In the event of a tax audit, you must be able to prove that the solutions applied comply with the law.
Settlements and reporting obligations
CIT taxpayers must keep detailed accounting records and file the required tax returns and declarations. The deadlines and forms of settlement are strictly set out in the Corporate Income Tax Act. For companies we keep accounting books and prepare CIT returns and financial statements — all within the scope of our accounting services.
Monthly CIT advance payments are the basic form of current settlement with the tax office. They are paid by the 20th of each month for the previous month, and small taxpayers and taxpayers in their first year of business may pay quarterly advances – by the 20th of the month following the quarter (Article 25(1)–(1c) of the CIT Act). The amount of the advance payments depends on the income earned since the beginning of the tax year.
The annual CIT-8 tax return is the basic settlement in which the taxpayer presents a full picture of its tax position for the year. It is filed electronically by the end of the third month of the following year, and by the same deadline the taxpayer pays the tax or the difference between the tax due and the sum of advance payments (Article 27(1) and (1c)). For 2026 (tax year = calendar year), the deadline is 31 March 2027.
CIT obligations include paying advance payments (without filing monthly returns), filing the annual CIT-8 return and providing additional information when using tax preferences. Accounting books are sent in the JPK_CIT format (SAF-T file) – by the end of the seventh month after the end of the tax year (Article 9(1c) of the CIT Act as worded from 1 July 2026, Dz.U. 2026, item 779) – for the first time for the tax year beginning in 2025 (tax capital groups and taxpayers with revenue above EUR 50 million), in 2026 (taxpayers filing JPK_V7) or in 2027 (all others) – Article 66(2) of the Act of 29 October 2021 (Dz.U. 2021, item 2105) as worded by Dz.U. 2023, item 1059. The deadlines for filing documents are strictly binding
Special reporting obligations apply to taxpayers using Estonian CIT and other forms of preferential taxation. A company on Estonian CIT files the CIT-8E return on its income for the previous year by the end of the third month of the tax year (Article 28r(1)).
The CIT-8 return can only be filed electronically (Article 27(1c)). IT systems allow documents to be processed faster and reduce the risk of formal errors.
