Blog

Tax Residence Certificates in Poland – What Expats and Businesses Need to Know If you earn income in Poland or receive payments from a Polish company, one document is crucial to avoid double taxation and ensure the correct application of tax treaties – the tax residence certificate. For foreign individuals and companies, this certificate proves where you are a tax resident and determines which country has the right to tax your income. Without it, Polish payers are often required to withhold tax at standard rates (19% or 20%), even if a tax treaty provides a lower rate or exemption.

During a press conference on 31 July 2025, Finance Minister Andrzej Domański announced the introduction of the Personal Investment Account (OKI). The new product is intended to enable investing and saving without capital gains tax (the so-called Belka tax) up to PLN 100,000 accumulated in the OKI.

No more artificial suspension of the limitation period by initiating criminal tax proceedings. In the latest version of the draft amendment to the Tax Ordinance, the Ministry of Finance has proposed removing the provisions allowing tax authorities to suspend the limitation period for tax liabilities solely on the basis of initiating proceedings for a fiscal offence or fiscal misdemeanour (Article 70 § 6(1) of the Tax Ordinance). For many years, this provision has enabled the tax administration to effectively extend the limitation period for tax liabilities, even in situations where there was no real need to initiate criminal proceedings.

On 18 September 2025, an act amending the Energy Law will come into force, which also includes an amendment to the CIT Act. In response to numerous interpretative disputes, the legislator clearly confirms that emission-free mergers of so-called ‘sister companies’ are tax neutral.

Withholding tax (WHT) in Poland has undergone significant changes in recent years. Since 1 January 2022, a new mechanism called “pay and refund” applies to certain cross-border payments. This system has major implications for foreign investors, expats, and multinational companies receiving dividends, interest, or royalties from Poland.

What will change? The draft introduces a restriction on the exemption from taxation of the sale of property by a family foundation in order to prevent the use of foundations for quick, tax-neutral sales of assets. Income from the sale of property contributed free of charge or acquired from a related entity by a family foundation will be subject to 19% CIT if it occurs within 36 months.

Moving to Poland for work or business can be a big step, but it comes with a powerful tax incentive. Under the Polish Return Tax Relief (ulga na powrót), individuals who become Polish tax residents after living abroad can enjoy up to PLN 85,528 of tax-free income each year for four consecutive years.That’s over PLN 342,000 of completely tax-free income. This benefit applies both to both employees and entrepreneurs, making it one of the most attractive relocation incentives in Europe.MartiniTax helps both expats and returning Polish citizens to qualify for the relief with all the steps necessary.

The IP Box (Innovation Box) is a special tax regime introduced in Poland in 2019 under the Corporate Income Tax Act and the Personal Income Tax Act. It allows qualifying income from eligible intellectual property to be taxed at a preferential 5% rate instead of the standard rates (19% /9% CIT and 12%-32% PIT or 19% PIT). The aim is to encourage innovation, R&D, and the development of new technologies in Poland.