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Reporting obligations of real estate companies and their shareholders

As the end of the tax year approaches, we would like to remind you of the reporting obligations applicable to real estate companies and their shareholders. One of the initial steps is to verify whether a given entity qualifies as a real estate company in 2025.
Author:
Radosław Druć
Head of TAX Department
Łukasz Kaza
Junior TAX Consultant

In connection with the approaching end of the tax year, we would like to remind you of the reporting obligations applicable to real estate companies and their shareholders.

We kindly inform you that one of the first steps in this process is to determine whether a given entity meets the definition of a real estate company for 2025.

If the definition of a real estate company is met, the reporting obligations include, inter alia, the filing of the following declarations:

  1. CIT/PIT-N1 declaration – filed by the real estate company, in which direct and indirect shareholders holding at least 5% of the rights in the company are disclosed;
  2. CIT/PIT-N2 declaration – filed by direct and indirect shareholders holding at least 5% of the rights in the real estate company.

The deadline for filing the above declarations is 31 March 2026.

How to report a real estate company in 4 steps

  1. Status audit: Verify whether you meet the definition of a real estate company based on historical data.
  2. Review of the group structure: Identify indirect and direct shareholders subject to reporting.
  3. Verification of identifiers: Check whether foreign entities hold the required NIP/PESEL numbers.
  4. Submission of forms: Prepare and submit the declarations electronically, ensuring compliance with the statutory deadline.

By when must the report be filed and what are the sanctions?

For entities whose tax year coincides with the calendar year, the deadline for reporting real estate companies expires at the end of the third month following the end of the year—that is, no later than 31 March 2026.

Failure to comply with this obligation exposes individuals responsible for financial matters to fiscal penal liability. Penalties resulting from the Fiscal Penal Code (KKS) may be financially severe and may apply directly to members of the management board.

One of the most common reasons for failure to meet reporting deadlines is the lack of a Polish tax identification number (NIP). Foreign entities required to file the CIT-N2 declaration must hold a Polish NIP, and the procedure for obtaining a NIP for non-residents may take several weeks. For this reason, we recommend verifying whether a NIP has been obtained well in advance.

KR Group support

KR Group will be pleased to provide you with:

  • support in verifying whether a company qualifies as a real estate company;
  • comprehensive assistance in the preparation and filing of the required declarations if such status is confirmed.

Under separate arrangements, KR Group may also provide support in obtaining a Polish NIP for foreign entities.

Should you have any questions, we remain at your disposal.

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