GrantThornton - regions

How to Safely Distribute Dividends from Poland

Dividend payments by Polish companies to non-resident shareholders require careful withholding tax analysis. Although exemptions under the Parent-Subsidiary Directive or reduced treaty rates may apply, the Polish tax authorities’ approach and the “pay-and-refund” regime for payments exceeding PLN 2 million often make due diligence, supporting documentation, and beneficial owner verification essential for determining the correct tax treatment.

Dividend payments by Polish companies to non-resident shareholders require careful withholding tax analysis. Although exemptions under the Parent-Subsidiary Directive or reduced treaty rates may apply, the Polish tax authorities’ approach and the “pay-and-refund” regime for payments exceeding PLN 2 million often make due diligence, supporting documentation, and beneficial owner verification essential for determining the correct tax treatment.


Home Office and Permanent Establishment in Poland – A Favourable Supreme Administrative Court Ruling for Foreign Companies (CASE STUDY)

Employing remote workers in Poland does not necessarily create a permanent establishment in Poland (PE) – this has been confirmed by the Polish Supreme Administrative Court (NSA) in its recent judgment of 28 October 2025 (case no. II FSK 163/23). The ruling, obtained for a Grant Thornton client, strengthens a favourable line of Polish case law and serves as an important reference point for foreign companies hiring remote employees in Poland.

Employing remote workers in Poland does not necessarily create a permanent establishment in Poland (PE) – this has been confirmed by the Polish Supreme Administrative Court (NSA) in its recent judgment of 28 October 2025 (case no. II FSK 163/23). The ruling, obtained for a Grant Thornton client, strengthens a favourable line of Polish case law and serves as an important reference point for foreign companies hiring remote employees in Poland.


Top-up Tax Poland

Poland submits Pillar II bill to Parliament on 25 September 2024. When approved by the parliament and signed by the president, the bill is expected to come into effect on 1 January 2025.

Poland submits Pillar II bill to Parliament on 25 September 2024. When approved by the parliament and signed by the president, the bill is expected to come into effect on 1 January 2025.


The National e-Invoice System (KSeF) – practical aspects

The Act introduces the mandatory National e-Invoicing System (in Polish: Krajowy System e-Faktur; the KSeF), i.e., the biggest revolution in invoicing that will change the current system of VAT settlements. From July 2024, the issue of invoices by VAT taxpayers to VAT taxpayers will be compulsory, and from 2025 failure to fulfill these obligations will be penalized.

The Act introduces the mandatory National e-Invoicing System (in Polish: Krajowy System e-Faktur; the KSeF), i.e., the biggest revolution in invoicing that will change the current system of VAT settlements. From July 2024, the issue of invoices by VAT taxpayers to VAT taxpayers will be compulsory, and from 2025 failure to fulfill these obligations will be penalized.


What are Poland’s Special Economic Zones, Polish Investment Zone and Public Support for Foreign Investors?

Poland's Special Economic Zones have been replaced by the Polish Investment Zone, which is a new tax relief mechanism. Since 2018, Poland has become one large special economic zone, offering income tax exemptions to enterprises, especially those involved in the establishment or expansion of production plants.

Poland's Special Economic Zones have been replaced by the Polish Investment Zone, which is a new tax relief mechanism. Since 2018, Poland has become one large special economic zone, offering income tax exemptions to enterprises, especially those involved in the establishment or expansion of production plants.


Tax Reliefs in Poland: R&D, IP Box, for prototype, for expansion, for robotization

In the Polish tax system there are reliefs that may prove attractive to enterprises planning innovative undertakings or investments in robotization. Also companies that launch…

In the Polish tax system there are reliefs that may prove attractive to enterprises planning innovative undertakings or investments in robotization. Also companies that launch…


Secondment vs. business travel

This article aims to differentiate between the concepts of employee secondment and business travel.

This article aims to differentiate between the concepts of employee secondment and business travel.


R&D tax relief and IP Box tax relief – 25 facts and myths

The R&D tax relief and IP Box tax relief are increasingly popular among taxpayers. No wonder – they offer attractive tax advantages. The R&D tax…

The R&D tax relief and IP Box tax relief are increasingly popular among taxpayers. No wonder – they offer attractive tax advantages. The R&D tax…