Taxation of an sp. z o.o.: CIT at 9% and 19%, Estonian CIT and dividends
When a company pays 9% CIT and when 19%, how advances and the CIT-8 work, what Estonian CIT is and how a shareholder's dividend is taxed in 2026.
Updated
An sp. z o.o. pays corporate income tax (CIT) on its income. When it pays profit out to shareholders as a dividend, the shareholder also pays PIT on it. This is the so-called double taxation.
The CIT rate: 9% or 19%
The standard rate is 19%. The 9% rate applies to income other than capital gains when both conditions are met:
- the company is a small taxpayer or is in its first year of activity;
- the company's revenue in the year did not exceed the equivalent of EUR 2,000,000.
| 2026 threshold | Amount | NBP rate |
|---|---|---|
| Small taxpayer: 2025 sales including VAT | up to PLN 8,517,000 | of 1 October 2025 |
| 2026 revenue for the 9% rate | up to PLN 8,431,000 | of 2 January 2026 |
The 9% rate does not apply, among others, to a company formed by converting a JDG, or one that received a business or business assets worth more than EUR 10,000, in the year it starts and the following year. Details and exceptions are in CIT at 9% or 19%.
Advances and the CIT-8
- You pay CIT advances monthly by the 20th of the following month. A small taxpayer and a company in its first tax year can pay quarterly.
- The advance for December or the fourth quarter is due by 20 January.
- You file the annual CIT-8 return and pay the balance by the end of the third month after the tax year, which for a calendar year is 31 March.
Dividends
A shareholder pays 19% PIT on a dividend. The company withholds it as the tax remitter. An example for PLN 100 of profit before tax:
| 9% CIT | 19% CIT | |
|---|---|---|
| Company CIT | PLN 9.00 | PLN 19.00 |
| Dividend | PLN 91.00 | PLN 81.00 |
| PIT on the dividend (19%) | PLN 17.29 | PLN 15.39 |
| Net to the shareholder | PLN 73.71 | PLN 65.61 |
Other ways to take money out of the company, such as pay for a board member, have their own taxes and contributions. See How to take money out of an sp. z o.o..
Estonian CIT
Estonian CIT (lump-sum tax on company income) moves the tax to the moment profit is paid out. As long as the profit stays in the company, the company pays no CIT.
- The rate: 10% for a small taxpayer and a company starting its activity, 20% for others.
- The shareholder pays 19% PIT on the dividend but deducts 90% (at the 10% rate) or 70% (at the 20% rate) of the lump-sum tax attributable to their share of the profit.
- Conditions: all shareholders are natural persons, the company holds no shares in other companies, less than half of its revenue is passive, and it employs at least 3 people who are not shareholders (a new company has time to meet this).
- You notify the tax office with the ZAW-RD form by the end of the first month of the tax year from which you want to apply it.
More: Estonian CIT in Poland. Norman does not settle Estonian CIT.
The company's books
The company keeps full accounting from the start. It prepares its financial statements within 3 months after the end of the financial year, the shareholders approve them within 6 months, and the board files them with the KRS within 15 days of approval.
In Norman
You set the CIT rate and the advance method under Account → Taxes. Norman calculates the advances from the company's books and prepares a draft CIT-8. See CIT in an sp. z o.o. and The sp. z o.o. ledger.
This is general information on the 2026 rules, not an analysis of your company. Before choosing Estonian CIT or a way to pay out profit, talk to an accountant or a tax adviser.
Sources: CIT Act, art. 4a(10), 19, 22, 25, 27 and 28c onwards, PIT Act, art. 30a, Accounting Act, art. 52, 53 and 69, NBP EUR rate of 1 October 2025, NBP EUR rate of 2 January 2026, podatki.gov.pl: CIT.