The tax on relocated profits applies to Polish companies making so-called passive payments (e.g. interest, advisory services, management fees, royalties, and similar) to related foreign entities. The tax payment deadline falls on March 31, 2026, so further steps should be taken in the coming weeks.
The obligation to pay the tax on relocated profits arises when both:
- the Polish taxpayer making payments from the catalogue of passive costs, and
- the related foreign entity receiving those payments,
meet all conditions set out in the Corporate Income Tax Act.
KR Group approach
To balance a reliable assessment of this specific tax exposure with cost efficiency, we apply a phased approach. First, we verify the statutory conditions at the level of the Polish entity, and only then, if necessary, proceed to the analysis at the level of the foreign entity.
This means that if the conditions are not met on the Polish entity side, the analysis is stopped to avoid generating additional costs. The next stage (foreign entity level) is initiated only if the first-stage analysis indicates that the tax obligation cannot be ruled out.
Scope of support
To assess whether the Company is subject to the tax on relocated profits, the first step is to verify whether the statutory conditions are met on the side of the Polish taxpayer making passive payments to related foreign entities.
