CIT 9% or 19% in 2026: who is a small taxpayer in Poland

In 2026, a Polish sp. z o.o. pays 9% CIT if it has small taxpayer status (sales revenue including VAT for 2025 up to PLN 8,517,000) and if its revenue earned in 2026 does not exceed PLN 8,431,000. All other companies pay 19%, and capital gains, such as dividends received, are always taxed at 19%.

Law as of 9 October 2026.

Both amounts are the equivalent of EUR 2,000,000, but they use a different exchange rate and measure different revenue. A company can therefore meet one condition and fail the other.

Two conditions for the 9% rate

The 9% rate applies to income other than capital gains. The company must meet two conditions at the same time.

1. Small taxpayer status (mały podatnik). Sales revenue including output VAT in the previous tax year did not exceed the equivalent of EUR 2,000,000. The amount is converted at the NBP (National Bank of Poland) average rate from the first working day of October of the previous year and rounded to PLN 1,000 (art. 4a pkt 10 and art. 19 ust. 1d of the CIT Act, ustawa o CIT).
2. Current-year revenue limit. Revenue earned in the tax year did not exceed the equivalent of EUR 2,000,000. Here the NBP rate from the first working day of the tax year applies, and revenue is counted without VAT (art. 19 ust. 1 pkt 2 lit. a and art. 12 ust. 4 pkt 9 of the CIT Act).

If the tax year is shorter or longer than 12 months, the second limit is prorated: 1/12 of EUR 2,000,000 times the number of full months in the tax year (art. 19 ust. 1 pkt 2 lit. b of the CIT Act). The small taxpayer limit has no such proration.

If revenue exceeds the limit during the year, the condition in art. 19 ust. 1 pkt 2 is not met for the whole year. The company then taxes all of that year's income at 19% in its annual return.

Limits for 2026 and 2027

The amounts come from NBP average rates (table A) rounded to PLN 1,000.

The 2027 amounts are calculated from the statutory formula and the published NBP rate. The 2027 revenue limit will only be known once the rate for the first working day of 2027 is published.

A new company in its first year

A company that starts business does not need small taxpayer status in its first year (art. 19 ust. 1e of the CIT Act). It has no revenue from a previous year. It must still stay within the current-year revenue limit, prorated if the first tax year is not 12 months long.

Example: a company registered in 2026 with first-year revenue below the limit pays 9%. In the second year, the 9% rate depends on both conditions, including sales revenue with VAT for the first year. Our guide How to start a sp. z o.o. covers founding the company and the steps after the KRS (National Court Register) entry.

Who cannot use 9%, even with low revenue

Companies created by restructuring or conversion

The 9% rate does not apply in the year business starts and the following year to a taxpayer created (art. 19 ust. 1a of the CIT Act):

1. by the conversion, merger or division of taxpayers, except the conversion of one company into another company (pkt 1);
2. by converting a sole proprietorship (jednoosobowa działalność gospodarcza, JDG) or a company without legal personality, such as a general partnership (spółka jawna) (pkt 2);
3. by shareholders contributing a business they previously ran, an organised part of it or its assets worth more than EUR 10,000 (pkt 3);
4. by non-cash contributions of assets received from the liquidation of other taxpayers in which the shareholders held shares (pkt 4).

Contribution in kind in the first two years

The same exclusion covers a company that received, in the year it was formed or the following year, a business, an organised part of a business or business assets worth more than EUR 10,000 (art. 19 ust. 1a pkt 5 of the CIT Act). Example: an entrepreneur founds a company with cash and a few months later contributes a car and equipment from their sole proprietorship worth PLN 60,000. The company loses the 9% rate for the year of formation and the following year.

Other exclusions

• Tax capital groups and family foundations never use 9% (art. 19 ust. 1b of the CIT Act).
• A divided company, and a company that contributed its business or business assets worth more than EUR 10,000 to another entity, loses 9% in the year of the division or contribution and the following year (art. 19 ust. 1c of the CIT Act).
• Banks and credit unions have their own rates from 2026 (art. 19 ust. 1 pkt 3–5 of the CIT Act).

Capital gains always at 19%

The 9% rate covers only revenue (income) other than capital gains (art. 19 ust. 1 pkt 2 of the CIT Act). The company taxes capital gains at 19%. They include, among others (art. 7b ust. 1 of the CIT Act):

• dividends and other income from a share in the profits of legal persons;
• revenue from selling shares;
• revenue from securities and derivatives;
• revenue from making a non-cash contribution to another company;
• revenue from exchanging virtual currencies.

The company therefore calculates income in two baskets. Operating income can be taxed at 9%, and capital gains income is always taxed at 19%.

Remember the second level of tax too. When the company pays a dividend to a shareholder who is an individual, the shareholder pays 19% tax on the dividend (art. 30a ust. 1 pkt 4 of the PIT Act). You can estimate the total cost of running a company, including taxes and ZUS (social security), with the company cost calculator.

CIT advance payments

Monthly or quarterly

The default is monthly advances paid by the 20th of the following month (art. 25 ust. 1 and 1a of the CIT Act). Small taxpayers and companies in their first tax year may pay quarterly advances by the 20th of the month after the quarter (art. 25 ust. 1b and 1c of the CIT Act). The company reports the choice of quarterly advances in its CIT-8 return for that year (art. 25 ust. 1e of the CIT Act).

The advance for the last month or quarter is due by 20 January. It does not have to be paid if the company files its return and pays the tax before that date (art. 25 ust. 1a and 1c of the CIT Act).

The rate in advances

Eligible small taxpayers and new companies may calculate advances at 9% for the months or quarters in which year-to-date revenue did not exceed the limit (PLN 8,431,000 in 2026). From the next month or quarter, they must apply 19% (art. 25 ust. 1f and 1g of the CIT Act).

Simplified advances

A company may pay monthly advances in simplified form: 1/12 of the tax due shown in the return filed in the previous year. If that return showed no tax due, the return from two years earlier is used (art. 25 ust. 6 of the CIT Act). Rules:

1. the simplified form applies for the whole tax year (art. 25 ust. 7 pkt 2 of the CIT Act);
2. the company reports the choice in its CIT-8 return for that year (art. 25 ust. 7a of the CIT Act);
3. companies that first started business in the previous year or the current year cannot use it (art. 25 ust. 8 of the CIT Act).

The Act provides simplified advances only in monthly form.

CIT-8 return and tax payment

The company files the CIT-8 return by the end of the third month after the tax year ends and, by the same date, pays the tax or the difference between the tax and the advances paid (art. 27 ust. 1 of the CIT Act). The return is filed electronically (art. 27 ust. 1c of the CIT Act).

With a tax year equal to the calendar year, the deadline for 2026 is 31 March 2027.

Bill: 22% CIT for the largest companies

A government amending bill (Sejm print no. 3147) proposes a new 22% rate from 2027. It would cover, among others, taxpayers with revenue for the previous year above the equivalent of EUR 50,000,000. The bill reached the Sejm on 29 September 2026, and on 6 October 2026 it passed its first reading and went to the Public Finance Committee.

This is not law in force. The bill can still change or never take effect. It does not change the 9% and 19% rates described above.

Frequently asked questions

Is the small taxpayer limit counted with VAT?

Yes. Small taxpayer status depends on sales revenue including output VAT for the previous year (art. 4a pkt 10 of the CIT Act). The current-year revenue limit in art. 19 ust. 1 pkt 2 is counted without VAT.

Does a new sp. z o.o. pay 9% CIT from the start?

Yes, if its revenue in the first tax year does not exceed the limit and no exclusion under art. 19 ust. 1a of the CIT Act applies. A company created by converting a sole proprietorship or by contributing a business worth more than EUR 10,000 pays 19% in the year it starts and the following year.

What happens if I exceed the revenue limit during the year?

From the next month or quarter, you calculate advances at 19% (art. 25 ust. 1g of the CIT Act). In the annual return, all income for that year is taxed at 19%, because the condition in art. 19 ust. 1 pkt 2 is not met.

Can a dividend received by the company be taxed at 9%?

No. A dividend is a capital gain (art. 7b ust. 1 pkt 1 of the CIT Act), and the 9% rate applies only to income other than capital gains. A dividend from a company based in Poland is taxed at 19% of revenue unless an exemption applies (art. 22 ust. 1 of the CIT Act).

What is the small taxpayer limit for 2027?

It is PLN 8,754,000, which is EUR 2,000,000 at the NBP rate of PLN 4.3770 on 1 October 2026. It is based on sales revenue including VAT for 2026.