Poland Corporate Income Tax Guide (CIT)

Poland's Corporate Income Tax (CIT / Podatek dochodowy od osób prawnych) applies a standard rate of 19%, with a reduced 9% rate for small taxpayers. Special regimes include IP Box (5% on qualifying IP income), generous R&D relief (ulga B+R), Polish Holding Company exemption, and an optional Estonian CIT model for retained profits. For related guidance, see our Personal Tax Guide → and VAT Guide →.

CIT Rates 2026

19% — standard CIT rate for all corporate taxpayers.
9% — reduced rate for small taxpayers (podatnicy CIT o statusie małego podatnika) with annual revenue below PLN 2 million (or €2 million equivalent). The 9% rate applies only to the portion of income derived from operational activity (not capital gains).

IP Box (Innovation Box — 5%)

Qualifying income from intellectual property rights (patents, copyright on software, utility models, industrial designs, etc.) can be taxed at an effective rate of 5%.
To benefit, the taxpayer must conduct qualifying R&D activities and properly document the nexus between R&D expenditure and IP income.
The IP Box is available to both CIT and PIT taxpayers (sole proprietors).

R&D Relief (Ulga B+R)

Taxpayers conducting research and development can deduct 100% of qualifying R&D costs from taxable income (200% for certain personnel costs).
Qualifying costs include: employee salaries (related to R&D), raw materials, expert opinions, depreciation of R&D assets, and acquisition of R&D services from external entities.
Unused relief can be carried forward for up to 6 years.

Polish Holding Company Exemption

A qualifying Polish Holding Company (spółka holdingowa) can benefit from a 95% exemption on dividends received from its qualifying subsidiaries.
Conditions: at least 10% shareholding held for 2+ years, both entities subject to CIT, and the subsidiary conducts actual business activity (not passive).
The exemption also applies to capital gains on disposal of shares in qualifying subsidiaries.

Estonian CIT (Ryczałt od Dochodów Spółek)

Poland offers an optional Estonian CIT model where corporate profits are not taxed until distributed as dividends (similar to the Estonian system).
The rate is 10% (standard) or 5% (small taxpayer/IP Box) on distributed profits.
Eligible entities: limited liability companies (sp. z o.o.) and joint-stock companies (S.A.) with revenue up to PLN 100 million, at least 3 employees, and meeting specific criteria.
Benefits include deferred taxation, simplified accounting, and no CIT on reinvested earnings.

Other Key CIT Provisions

Withholding tax (WHT): 19% on dividends, interest, and royalties to non-residents (reduced under tax treaties). A pay-and-refund system applies for WHT above certain thresholds.
Thin capitalisation: Interest deduction limited to 30% of EBITDA (tax EBITDA) for exceeding PLN 3 million in net interest costs.
Controlled Foreign Company (CFO): Polish CFC rules apply to foreign entities with passive income held by Polish tax residents.
Exit tax (podatek od wyjścia): 19% on unrealised gains when a company moves its seat or assets abroad.