CIT (Corporate Income Tax: podatek dochodowy od osób prawnych) is the tax paid by legal entities operating in Poland, most commonly a Sp. z o.o. (LLC-equivalent). Here’s what applies in 2026: the standard rate, the reduced rate for small taxpayers and start-ups, the Estonian CIT alternative, and the CIT-8 filing deadline.

Scope: who pays CIT

Every company with its registered office or management board in Poland is subject to CIT on its total income (Polish tax residency). Legal entities without an office or management board in Poland are subject to CIT only on income generated within Poland. There are no local (municipal) CIT surcharges on top of the central-government rate: CIT is levied uniformly across the country.

In particular, the following are subject to CIT:

  • limited liability companies: Spółka z ograniczoną odpowiedzialnością (Sp. z o.o.);
  • joint-stock companies: Spółka Akcyjna (S.A.);
  • limited partnerships: Spółka komandytowa, and limited joint-stock partnerships: Spółka komandytowo-akcyjna;
  • corporations in the process of formation, tax capital groups, and a few other entity types.

Act of 15 February 1992 on Corporate Income Tax (Journal of Laws 1992, No. 21, item 86, as amended): link to the original.

Foreign nationals and foreign-owned entities face the same CIT rules as Polish or EU-owned companies: there’s no separate, harsher regime for foreign capital.

CIT rates in 2026: 19% and 9%

The standard CIT rate in 2026 remains 19%. A reduced 9% rate applies to income other than capital gains, but only for two categories of taxpayers:

  • small taxpayers (mały podatnik): companies whose sales revenue (including VAT) in 2025 did not exceed PLN 8,517,000;
  • start-ups: companies in the tax year in which they began operating (with some exclusions, e.g. entities formed from a transformation of a sole-trader business, for two years).
Watch the current-year limit too: to keep the 9% rate throughout 2026, net revenue (excluding capital gains) must not exceed the equivalent of €2,000,000: PLN 8,431,000 in 2026. Exceeding this limit mid-year means switching to 19% for income from the beginning of the year, with a top-up payment (no penalty interest is due on the difference).

Capital gains are always taxed at 19%, regardless of a company’s small-taxpayer status: this includes income from the sale of shares, securities, virtual currencies, and dividends received. The same 19% standard rate applies to income from the sale of real estate, unless a specific exemption applies. Financial-services companies cannot use the 9% rate.

Estonian CIT: still available in 2026

Poland’s alternative flat-rate system for companies, ryczałt od dochodów spółek, commonly called “Estonian CIT”, remains available in 2026. Under this system, tax is due only when profit is actually distributed to shareholders (e.g., as a dividend), rather than on an accrual basis. The 2026 rates are:

  • 10%: for small taxpayers;
  • 20%: for other taxpayers.

Key conditions include: shareholders must be exclusively natural persons (no legal-entity shareholders), the company must not hold shares in other entities, it must keep full accounting records, and it must meet minimum-employment and revenue-structure requirements (limits on passive income such as interest or royalties). Estonian CIT and the classic 9%/19% system are mutually exclusive: a company chooses one or the other; switching requires a formal notification to the tax office.

Tax base

Under the CIT Act, the tax base is the company’s total income: the difference between taxable revenue and tax-deductible expenses. There’s no separate preferential treatment for capital gains: income from the sale of shares or other securities is taxed at the standard 19% rate, and the same applies to real estate sales unless a specific exemption is available.

Filing CIT-8

All CIT taxpayers must keep accounting records under the Accounting Act (Journal of Laws 1994, No. 121, item 591, as amended).

The annual CIT-8 return must be filed by the end of the third month following the tax year-end: that is, by 31 March for companies whose tax year matches the calendar year (so CIT-8 for 2025 is due by 31 March 2026). Any outstanding tax (the difference between tax due and advance payments made during the year) is also payable by that date.

CIT-8 must be filed electronically, through one of two channels:

  • the e-Deklaracje system, which requires a qualified electronic signature;
  • the e-Urząd Skarbowy portal (podatki.gov.pl), where you can authenticate with a trusted profile (ePUAP), online banking, the mObywatel app, or an e-ID: no qualified signature is required there.
Whoever signs the CIT-8 on the company’s behalf, including an accountant or accounting firm, must be registered with a power of attorney on form UPL-1 beforehand. Without it, the return cannot be validly submitted for the company.

A qualified electronic signature, if needed, can be purchased from an authorised provider: for instance, the “Szafir” signature issued by the National Clearing House (Krajowa Izba Rozliczeniowa, KIR).

Tax authorities may impose penalties for late filing, for failing to comply with reporting obligations, or for outstanding unpaid tax.

A Sp. z o.o. as a “second company” and the PIP 2026 reform

In some holding structures, a Sp. z o.o. (a CIT payer) sits alongside B2B contractors as a “second company”: for example, to hold IP, invoice larger clients, or manage a team. This kind of arrangement is increasingly reviewed under the 2026 PIP reform on B2B contract reclassification. See our series on this “two companies” model for more here.

FAQ

Can a foreign-owned company use the 9% CIT rate?

Yes: the same rules apply as for Polish or EU-owned companies, based on the small-taxpayer/start-up status and revenue thresholds, not on the origin of the shareholders’ capital.

Can I combine Estonian CIT with the 9% rate?

No. They are mutually exclusive systems: a company chooses classic CIT (19%, or 9% if eligible) or Estonian CIT (10%/20% on distributed profit), not both at once.

Bibliography and legal basis

  • Act of 15 February 1992 on Corporate Income Tax (Journal of Laws 1992, No. 21, item 86, as amended): original text.
  • Art. 19 (rates: 19%/9%), Art. 28j-28t (Estonian CIT conditions and rates), Art. 27(1) (CIT-8 deadline) of the CIT Act.
  • Accounting Act of 29 September 1994 (Journal of Laws 1994, No. 121, item 591, as amended).

Author: MojaFirma team.

This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific contract and individual circumstances. If something about your own situation isn’t quite clear, feel free to book a free consultation with our team.