Poland: flat-rate tax on foreign income, tax scale, linear tax and Estonian CIT

Poland taxes its residents on their worldwide income under a two-rate scale, 12%¹ then 32%² above PLN 120,000³ of taxable base (Ministry of Finance tables). The sole proprietor may prefer a linear tax of 19%⁴ or taxation on revenue.

Two schemes target newcomers. The lump sum under articles 30j to 30p releases foreign income from tax in return for PLN 200,000⁵ per year for up to up to 10 years⁶. The “ulga na powrót”, open to EU citizens, exempts business income up to up to PLN 85,528⁷ per year for up to 4 years⁸.

For companies, CIT is 19%⁹, reduced to 9%¹⁰ for small taxpayers; the “Estonian CIT” defers tax until profits are distributed.

Tax residence

A person is a Polish tax resident — and subject to unlimited tax liability — if they have the centre of their personal or economic interests in Poland, or if they stay there for more than more than 183 days¹¹ in the tax year (article 3 of the PIT Act, consolidated text Dz.U. 2026 poz. 592). The two criteria are alternative: staying for a shorter time does not protect someone whose family or business is in Poland. Non-residents are taxed only on their Polish income.

Tax scale and solidarity contribution

Income subject to the general rules — salaries, pensions, activities for which no election has been made — falls under the scale: 12%¹ up to PLN 120,000³, reduced by a tax reduction of PLN 3,600¹²; 32%² on the excess (podatki.gov.pl, stawki i limity). In practice, the flat-rate reduction produces a first portion of income that is not taxed.

Above more than PLN 1,000,000¹³ of combined income from the tax scale, linear tax, capital gains on securities and income of controlled foreign companies, a solidarity contribution of 4%¹⁴ applies to the excess (Ministry of Finance explanations, 2019). This is article 30h; the lump sum for new residents falls under articles 30j to 30p.

Capital income

Dividends and interest bear a flat-rate tax of 19%¹⁵; capital gains on the sale of securities are taxed at 19%¹⁶ and are reported on form PIT-38 (podatki.gov.pl). This income is not added to the scale. For dividends of French source, the tax treaty limits French tax to up to 15%¹⁷; its credit against Polish tax has not been detailed here.

Real estate

The sale of a property is taxed at 19%¹⁸ of the income when it takes place before 5 years¹⁹ counted from the end of the year of acquisition or construction; the income is exempt if it is used for the taxpayer's own housing needs within up to 3 years²⁰ (podatki.gov.pl, zbycie nieruchomości). The return is filed on form PIT-39.

Rent from private letting is taxed on gross receipts: 8.5%²¹ up to PLN 100,000²² of annual receipts, 12.5%²³ above.

Inheritance and gift taxes (podatek od spadków i darowizn) have not been verified in a source read for this page.

The lump sum on foreign income (articles 30j to 30p)

A person who transfers their tax residence to Poland may opt for an annual lump sum of PLN 200,000⁵, independent of the amount of their foreign income. The lump sum covers all income obtained abroad, except that of controlled foreign companies; no declaration of this income is required. In the year of arrival, it is calculated pro rata to the months of residence; it is paid no later than 30 April of the following year (government Q&A on the “Polski Ład”).

The conditions:

• not having been a Polish tax resident for at least from 5 years²⁴ of the 6 years²⁵ preceding the transfer — the years need not be consecutive;
• filing the PIT-PZ election form no later than the end of January of the year following the transfer, with a certificate of residence;
• spending each year at least from PLN 100,000²⁶ in support of economic growth, science and education, cultural heritage or physical culture, in accordance with a ministerial regulation, and providing proof of it before the end of January of the following year.

The regime applies for up to 10 years⁶. It ends earlier in the event of renunciation (form PIT-RPZ, before the end of January), change of residence, late payment or failure to make the required expenditure. A family member may in turn opt for their own lump sum of PLN 100,000²⁷ per year.

The calculation is straightforward: the lump sum is advantageous only if the normal Polish tax on foreign income, after credit for foreign taxes, durably exceeds the lump sum plus the mandatory expenditure. For income already taxed in its country of source, the advantage may be nil.

The official text of chapter 6b could not be read on the Dziennik Ustaw: the reading tool returns the consolidated text (Dz.U. 2026 poz. 592) only as far as article 14. The amounts and durations are based on the government Q&A, which are undated; their retention in the 2026 text was confirmed on a private reproduction. The regulatory list of eligible expenditure has not been read.

The ulga na powrót

The “return relief” exempts salaries, mandate contracts concluded with a company and income from economic activity up to up to PLN 85,528⁷ per year, for up to 4 years⁸ in a row starting, at the taxpayer's choice, from the year of settlement or the following year (podatki.gov.pl, ulga na powrót). It does not cover business management contracts.

Despite its name, it is not reserved for Poles: the nationality condition is met by a citizen of the European Union, the EEA or Switzerland, and an alternative route exists for those who previously resided in a listed country or in Poland. The person must also not have had a domicile in Poland during the from 3 years²⁸ (calendar years) preceding the year of return, have arrived after 31 December 2021 and provide a certificate of residence. The relief can be used only once, and its ceiling is shared with the exemptions for young people, large families and active seniors.

The ulga na powrót and the lump sum target different groups: the former reduces tax on modest to average income from work, while the latter is worthwhile only for high foreign income.

Sole proprietorship: three regimes and heavy contributions

A sole proprietor can stay on the progressive scale, opt for the 19%⁴ flat tax on profit, or opt for the ryczałt on revenue, with no deduction of expenses. The ryczałt is available if the previous year's revenue did not exceed up to €2,000,000²⁹, i.e. up to PLN 8,517,200³⁰ for an option exercised in 2026 (biznes.gov.pl, podatki.gov.pl). Its rates depend on the activity:

• liberal professions: 17%³¹;
• certain intangible services: 15%³²;
• other listed services: 14%³³;
• certain IT services: 12%³⁴;
• service activities, in particular: 8.5%³⁵;
• production and construction, in particular: 5.5%³⁶;
• trade and catering, in particular: 3%³⁷.

The ryczałt is excluded in particular for a pharmacy, currency exchange, trade in car parts, excise goods and services provided to a former employer.

The health contribution varies according to the regime (ZUS analysis, February 2026): 9%³⁸ of income on the progressive scale, 4.9%³⁹ under the flat tax, with a minimum of from PLN 432.54⁴⁰ per month in 2026. Under the ryczałt, it is a fixed amount depending on cumulative revenue: PLN 498.35⁴¹ per month up to PLN 60,000⁴², PLN 830.58⁴³ up to PLN 300,000⁴⁴, and PLN 1,495.04⁴⁵ beyond.

Social security contributions come on top: on the minimum base of from PLN 5,652⁴⁶, they amount to PLN 1,788.29⁴⁷ per month in 2026, excluding the Labour Fund. A business founder is exempt from them for up to 6 months⁴⁸ (ulga na start, the health contribution remaining due), and can then pay preferential contributions of PLN 456.18⁴⁹ per month for up to 24 months⁵⁰.

The choice therefore depends on the level of expenses and income: the ryczałt suits an activity with low expenses, the flat tax a profitable activity with deductible expenses, taking into account the health contribution specific to each regime.

Capital company: general CIT

A company that has its registered office or management in Poland is taxed on all its income, wherever it is earned. The rate is 19%⁹. A rate of 9%¹⁰ applies to income other than capital gains of a start-up company or a small taxpayer, if the revenue for the financial year does not exceed up to €2,000,000⁵¹ (podatki.gov.pl, CIT). Small taxpayer status in 2026 requires 2025 revenue below up to PLN 8,517,000⁵².

The dividend paid to a shareholder who is an individual is then taxed at 19%¹⁵.

Estonian CIT

The ryczałt od dochodów spółek removes corporate income tax as long as profit stays in the company: tax is due on distribution, at a rate of 10%⁵³ for a small taxpayer or a start-up company and 20%⁵⁴ for the others (podatki.gov.pl, rates and limits in Estonian CIT). A shareholder who receives the dividend reduces their own tax by 70%⁵⁵ of the tax paid by the company, or by 90%⁵⁶ for a small taxpayer (the ministry's investor guide, legal position as at 1 January 2026).

The conditions (podatki.gov.pl, basic information):

• shareholders who are exclusively individuals, and no shareholding in the capital of another company;
• at least from 3⁵⁷ full-time-equivalent jobs for at least from 300 days⁵⁸ in the year, or equivalent remuneration expenses under other contracts;
• passive income in the previous year below less than 50%⁵⁹ of revenue;
• election of 4 years⁶⁰, by means of the ZAW-RD notice filed before the end of the first month of the first year.

The regime is therefore not suited to a company held by a holding company, an investment management company or a structure with no employees.

Since 1 January 2025, Poland has applied the Act of 6 November 2024 on top-up taxation of groups (Pillar Two), according to the ELI record of the act. It concerns only large groups reaching the directive's consolidated turnover threshold, never a single SME.

The threshold and minimum rate of the Polish Pillar Two law were not read in the text (the Dziennik Ustaw website was inaccessible to the tool); neither the controlled foreign company rules nor the IP Box have been detailed in this page.

A French national, like any citizen of the European Union, can settle in Poland without a visa. Beyond more than 3 months⁶¹ of stay, they must register their stay, in person, with the voivode of their place of residence, no later than the day after the expiry of that period (Ministry of the Interior). They must show proof of employment, an activity, or sufficient resources and health insurance. Poland is part of the Schengen area, but not of the eurozone.

A third-country national needs a temporary residence permit, granted for at most up to 3 years⁶², in particular to work, carry out an economic activity, study or join family (Powroty government portal). The EU Blue Card is a variant of the temporary residence permit for highly qualified jobs.

The conditions for permanent residence of EU citizens and for long-term resident status, procedural fees and processing times have not been verified in any official source that could be read (the Office for Foreigners portal refuses automated reading).

The year of transfer is decisive. For the lump sum, it starts the maximum duration, fixes the proration of the first lump sum and the option deadline (end of January of the following year). For the ulga na powrót, it determines the starting point of the exemption period, at the taxpayer's choice.

Both schemes require prior non-residence proven by a foreign certificate of residence: over 6 years²⁵ for the lump sum, over from 3 years²⁸ (calendar years) for the ulga na powrót. A person who kept the centre of their interests in Poland during a period abroad may not meet the condition.

Between France and Poland, the convention of 20 June 1975, as modified by the multilateral convention (text published by impots.gouv.fr), resolves dual residence first by the permanent home and then by the centre of vital interests. It reserves interest and private pensions to the State of residence; dividends may be taxed at source up to up to 15%¹⁷, or up to 5%⁶³ for a company holding at least from 10%⁶⁴ of the capital. For a resident of France, double taxation is eliminated by a tax credit for dividends, royalties and a few other income items of Polish origin, and by exemption for other income taxable in Poland.

On leaving Poland, an exit tax applies to unrealised capital gains when the market value of the assets transferred exceeds more than PLN 4,000,000⁶⁵, at a rate of 19%⁶⁶ or, in certain cases, 3%⁶⁷ (form PIT-NZ). The lump sum ends at the close of the year preceding the change of residence.

The exit tax rules (reduced-rate cases, instalments, interplay with the lump sum) were read only on the ministry form, whose version refers to the 2022 consolidated text, and not in Article 30da as currently in force.

No official data on the cost of living or property prices could be read: the statistical office (GUS, stat.gov.pl) pages on housing prices refuse automated reading. The GUS indices should be consulted directly before any decision.

1. Obtain, before arrival, the tax residence certificates for previous years from the country or countries of prior residence.
2. Register the stay with the voivode if you are an EU citizen and the stay is extended, then obtain the identifiers needed for tax procedures (PESEL or NIP).
3. For the lump sum: file the PIT-PZ declaration by the end of January of the year following the transfer at the latest, pay the lump sum before 30 April of each following year, and document the expenditure before the end of January.
4. For the ulga na powrót: gather the certificate of residence and choose the starting year of the period.
5. For a sole proprietor: choose the regime before the twentieth day of the month following the first revenue of the year, and work out social security contributions and the health contribution.
6. For a company under Estonian CIT: file the ZAW-RD notice before the end of the first month of the chosen financial year and check the employment condition every year.

• The lump sum covers neither Polish income nor that of controlled foreign companies.
• Missing a year of expenditure or payment means losing the lump sum.
• The ulga na powrót ceiling is shared with other exemptions of the same type.
• The lump sum is often presented as “Article 30h”: this is incorrect, Article 30h concerns the solidarity contribution.

Does the lump sum cover my salary from a job performed in Poland?

No. Only income earned abroad falls under the lump sum; a salary for work performed in Poland follows the progressive scale.

Can a French national benefit from the ulga na powrót?

Yes, if they meet the other conditions: nationality of a Member State of the Union is enough, provided they did not have a domicile in Poland during the preceding from 3 years²⁸ (calendar years) and settle after 31 December 2021. The exemption is capped at up to PLN 85,528⁷ per year.

Must I never have lived in Poland to use the lump sum?

No: it is enough not to have been resident there for at least from 5 years²⁴ of the 6 years²⁵ preceding the transfer.

Is the mandatory expenditure an additional tax?

It is not a tax, but an annual expenditure of at least from PLN 100,000²⁶ in areas set by regulation, without which the regime is lost.

Does Estonian CIT eliminate the tax?

No: it defers it until distribution, at a rate of 10%⁵³ or 20%⁵⁴ depending on the size of the company, and the shareholder then credits part of that tax against their own.

Does a small activity under the ryczałt escape contributions?

No. After the relief periods, the entrepreneur pays social security contributions on a minimum base and a fixed health contribution, from PLN 498.35⁴¹ per month under the ryczałt in 2026.