This is a page for the tag Estonian CIT
Estonian CIT rulings in Poland – Supreme Administrative Court (NSA) on dividends, hidden profits and bond contributions
Recent Estonian CIT rulings in Poland by the Supreme Administrative Court (NSA) clarify several important aspects of the Polish lump-sum corporate taxation regime. When dividends are distributed, PIT must be calculated on the full amount of profit allocated to the shareholder, while the company’s Estonian CIT liability is accounted for... Read More →
Estonian CIT tax audits in Poland – what irregularities are tax authorities finding?
Estonian CIT tax audits in Poland focus primarily on whether companies have validly elected the lump-sum taxation of corporate income and continue to satisfy the applicable eligibility requirements. Ministry of Finance data published in May 2026 shows that tax authorities identified irregularities involving ZAW-RD notifications, mid-year elections, employment conditions, shareholder... Read More →
Tax changes in Poland 2027 for businesses: what will change in PIT, CIT and lump-sum tax?
The planned tax changes in Poland 2027 include a new PIT scale, a 22% CIT rate for the largest taxpayers, restricted access to the lump-sum tax on recorded revenue and new taxation rules for certain related-party transactions. The revenue threshold for choosing the lump-sum regime is planned to fall from... Read More →
Transfer pricing documentation and Estonian CIT in Poland – what the Supreme Administrative Court of Poland (NSA) ruling means for companies
Companies that have chosen the lump-sum taxation on corporate income in Poland, commonly referred to as Estonian CIT, still need to analyse their transfer pricing obligations. The issue of transfer pricing documentation and Estonian CIT is particularly important for companies operating within capital groups, companies with foreign shareholders and businesses... Read More →
Company car in Estonian CIT in Poland – when 50% of expenses become hidden profit
A company car in Estonian CIT in Poland is often treated as a standard business tool. It may be used by managers, sales staff, management board members and employees responsible for client relations. The problem arises, however, when a company applies the Polish lump-sum taxation regime on company income commonly... Read More →
Partner remuneration for managing the company as hidden profits in Estonian CIT in Poland
Hidden profits in Estonian CIT in Poland are becoming an increasingly practical risk area — especially where a company (or partnership taxed under the Estonian model) settles recurring benefits with its partners. An amending interpretation issued by the Head of the National Revenue Administration (KAS) on 7 November 2025 (ref.... Read More →
Switching to Estonian CIT in Poland requires timeliness – even a minor delay may disqualify a taxpayer
Estonian CIT is a preferential corporate tax regime available in Poland, offering a simplified way to settle accounts with the tax office and reduce accounting obligations. Its benefits are substantial — tax deferral on reinvested profits, fewer formalities, and improved liquidity.However, switching to this regime requires strict compliance with formal... Read More →
Restructuring and transformation of a limited partnership into a limited liability company
On January 22, 2024, a statement was issued regarding the release by the Head of the National Tax Administration (KAS) of a protective opinion dated November 29, 2023, concerning the process of a partner withdrawing from a limited partnership and transforming it into a limited liability company, opting for taxation... Read More →
Amendments to the Corporate Income Tax Act and certain other acts (Polish Deal 3.0)
Published on 25 October 2022, the Act of 7 October 2022 introduces new regulations for taxpayers. For the most part, the changes under the Act apply to CIT and come into force on 1 January 2023, with some exceptions (Polish Deal 3.0). A particularly significant change is the exemption from... Read More →
