The following overview provides a detailed analysis of Poland’s corporate tax regime for 2025. This information is tailored for internationally minded business professionals interested in the Polish fiscal environment for corporate entities.
Corporate Tax Rate Structure in Poland (2025)
Poland imposes a standard corporate income tax (CIT) applied at a flat rate on company profits. The system is primarily flat, with targeted reduced rates and additional surtaxes for specific business circumstances.
| Tax Category | Rate (%) | Condition / Applicability |
|---|---|---|
| Standard CIT | 19% | Flat rate on corporate profits |
| Reduced CIT | 9% | Small taxpayers (annual sales including VAT ≤ PLN 2 million (≈$487,000, using 1 USD ≈ 4.1 PLN)) or new businesses in their first tax year, on non-capital gains income |
| Minimum Income Tax | 10% | For companies with tax losses or income ≤ 2% of revenue; calculated on 1.5% of operational revenue plus certain costs, or optionally 3% of operational revenues |
| Estonian CIT Regime (Non-small taxpayers) | 20% | Tax on distributed profits and certain events |
| Estonian CIT Regime (Small taxpayers/new businesses) | 10% | Tax on distributed profits and certain events |
| Diverted Profits Tax | 19% | Applies to certain deductible payments to non-resident related entities |
| Minimum Tax on Buildings | 0.42% | Annual tax for buildings with initial value > PLN 10 million (≈$2.44 million) |
| Global Minimum Tax (Pillar 2 / QDMTT) | 15% | For groups with annual revenue ≥ €750 million (≈PLN 3.23 billion, ≈$809 million); top-up tax if effective tax rate < 15% |
Assessment Basis and Taxable Entities
The corporate tax in Poland is assessed on the profits of legal entities conducting business within Poland. Tax is levied based on corporate profits, with standard and preferential rates depending on company size and revenue.
Key Surtaxes and Special Regimes
- Reduced 9% CIT for Small Taxpayers: Available for companies with annual sales (including VAT) not exceeding PLN 2 million (approx. $487,000). New companies also benefit from this rate in their first tax year for non-capital gains income.
- Estonian CIT Regime: Instead of classic profit taxation, taxation is triggered on distributed profits and certain events. Small taxpayers and new businesses pay 10%; other taxpayers pay 20%.
- Minimum Income Tax: Applies at 10% (or alternatively at 3% of operational revenues) if a company declares a tax loss, or income not exceeding 2% of its revenues. The tax base includes operational revenues plus certain excessive costs.
- Diverted Profits Tax: At 19%, this tax targets qualified costs paid to non-resident related parties under specific conditions.
- Minimum Tax on Buildings: Imposed at 0.42% annually on the initial value of buildings exceeding PLN 10 million (≈$2.44 million).
- Global Minimum Tax: Poland aligns with Pillar 2 rules: a 15% minimum effective tax rate applies to multinational groups with consolidated revenue of at least €750 million (≈PLN 3.23 billion, ≈$809 million).
Brackets and Holding Periods
Poland operates a flat-rate corporate tax system. There are no progressive brackets for CIT, and no statutory minimum or maximum holding periods are specified in the current framework for rate eligibility. If information about holding periods is needed, current data is not publicly available.
Comparison Table: Selected Tax Elements (2025)
| Element | Rate (%) | Threshold / Notes |
|---|---|---|
| Standard CIT | 19% | All companies not qualifying for other rates |
| Reduced CIT (Small Taxpayers) | 9% | PLN 2 million (≈$487,000) sales (inc. VAT) |
| Estonian CIT (Small Taxpayers/New Businesses) | 10% | Taxation on distributed profits/events |
| Estonian CIT (Other) | 20% | Taxation on distributed profits/events |
| Minimum Tax on Buildings | 0.42% | PLN 10 million valuation (≈$2.44 million) |
| Global Minimum Tax | 15% | Groups with revenue ≥ €750 million (≈$809 million) |
Pro Tips for Navigating Corporate Tax in Poland
- Verify whether your company qualifies for the 9% reduced rate—review both turnover and VAT-inclusive sales figures against the PLN 2 million (≈$487,000) threshold each fiscal year.
- If your entity is facing low profitability or reporting tax losses, assess the minimum income tax impact and prepare additional reporting for excessive costs and operational revenues.
- For capital-intensive businesses with significant real estate holdings, factor in the 0.42% annual building tax above PLN 10 million (≈$2.44 million) into your ongoing cost projections.
- Evaluate the Estonian CIT regime, especially for cash-flow focused companies: taxation only on profit distributions may present planning advantages.
- Large multinational groups should conduct a Pillar 2 assessment to remain compliant with the 15% minimum effective tax and related reporting obligations.
Official Resources
For regulatory details, legislative updates, and official guidelines regarding taxes and business entities, refer directly to the Polish Ministry of Finance’s homepage: https://www.gov.pl/web/finance
In summary, Poland’s corporate tax regime as of 2025 is built on a flat standard rate, with targeted reduced rates and layered surtaxes for specific scenarios. There is no progressive bracket system for company profits; rather, the landscape is defined by turnover-based thresholds and specific conditions. Planning for tax in Poland requires awareness of both the main corporate rate and the suite of minimum and special taxes applicable to particular business profiles or structures.