Why Tax Strategy Matters in 2025
With rising tax complexity in Poland, optimizing your corporate tax approach is no longer optional. In 2025, three paths stand out:
- The 9% CIT rate for eligible businesses
- The minimum income tax for loss-making firms
- The Estonian CIT regime, allowing tax deferral
Choosing the right method can lower costs, improve liquidity, and avoid compliance risks.
PICTURE 1
The 9% CIT Rate – For Small Taxpayers and New Firms
Poland’s reduced 9% CIT applies if:
- You qualify as a small taxpayer (revenue ≤ EUR 2 million in the previous tax year) or you’re in your first tax year
- Your revenue is from business operations (not capital gains)
The EUR 2 million cap for small taxpayer status is converted to PLN using the NBP rate on the first working day of October each year.
Ineligible entities include those from a number of restructurings.
Pro Tip: Monitor revenues closely and analyze restructurings if planning to apply the 9% rate.
Minimum Income Tax – What’s New in 2024
Applicable since 2024, this specific tax targets:
- Companies with operational losses
- Firms with ≤ 2% income-to-revenue ratio
Tax base includes:
- 1.5% of operating revenue
- Excess interest and service costs to related parties
Simplified method for tax base: 3% of operational revenue
Tax rate: 10%
Exemptions include among others::
- First 3 years of business
- Small taxpayers
- ≥30% drop in revenue
Tip: Review EBITDA and income margins regularly to stay above risk thresholds. Review tax exemptions strategically to minimize exposure to minimum income tax.
PICTURE 2
Estonian CIT – A Deferred Taxation Model
Key idea: No CIT until profit is distributed (e.g. dividends)
Advantages:
- Improves cash flow
- Simplifies tax reporting
- Lower combined CIT + PIT rates (20–25%)
Eligibility:
- Only individual shareholders
- Active business income
- No holdings in other entities
- Proper employment structure
- Timely notification to the tax authorities
Best for: Companies reinvesting profits over several years.
Summary – Which CIT Model Fits You Best?
| Option | Best For | Key Benefit |
| 9% CIT | Small or new companies | Lower tax rate |
| Minimum Tax Planning | Firms with slim margins | Compliance and forecasting |
| Estonian CIT | Growth-driven SMEs | Tax deferral and liquidity |
Strategic tax planning helps avoid unnecessary costs and maintain long-term financial health. Consult tax professionals to model outcomes before selecting a tax regime.
Want the Full Picture?
Explore our comprehensive blog post covering everything you need to know about Corporate Income Tax (CIT) in Poland – from standard rules to hidden exemptions.
FAQs – CIT, Estonian CIT in Poland
Can I switch between 9% CIT and Estonian CIT?
Yes, but it involves preparing a financial statement and providing a CIT return for the period from the start of the year until the day before the new tax system is introduced.
Is Estonian CIT suitable for holding companies?
No – only for operating companies with no shareholdings.
What if I exceed the 9% CIT revenue threshold?
You revert to the 19% standard rate.
Is the minimum tax additional to CIT?
It’s an alternative floor – if standard CIT is lower, you pay the minimum instead.