Challenges and opportunities - new rules in the Polish Investment Zone

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Challenges and opportunities - new rules in the Polish Investment Zone

Sponsored by

sponsored-firms-mddp.png
coins-948603 resized.jpg

Bartosz Głowacki of MDDP analyses the new rules surrounding the Polish Investment Zone, with significant tax windfalls to be found by intrepid investors.

From January 1 2023 there are new rules on regional investment state aid in the Polish Investment Zone. The Polish Investment Zone provides corporate income tax exemption in return for investment in specific regions. It applies to all types of taxpayers, such as individuals, partnerships, companies and other corporate bodies.

Part of the expenses incurred by making new investments returns via the personal income tax/ corporate income tax exemption. One may also ask for a state aid decision, valid for between 10 to 15 years. The amount of the exemption depends on the region, the value of the investment and the size of the enterprise. In general, the smaller the enterprise and the poorer the region, the bigger the exemption.

The most important change is that now the exemption applies only after the declared investment is completed, and it must be finished within three years. Previously, investors were allowed to benefit from the exemption right after first investment costs had been incurred and profit earned. That worked if the investment was made in parts that could operate separately before the process ended (like one production line out of many planned). Thanks to that approach the Polish Investment Zone (PIZ) allowance was more efficient. Now the exemption period will be shorter, and investors will be taxed if the investment starts to operate but is not formally finished. Further, even if the investment is completed before the deadline outlined in the support decision, this will not make the tax exemption available earlier.

Although the PIZ is available in most of Poland, there are some regions where it is not. Large enterprises will not be granted support for investments in the Wielkopolskie and Dolnośląskie regions as well as communes in Mazowieckie.

The list of sectors which do not qualify for PIZ exemptions has been also extended. For example, no-one will obtain support to produce weapons and ammunition.

What may be welcomed is that the minimum required investment value in the development of already existing business is now reduced by 50% for all. Previously, only medium and large enterprises could qualify for that discount. Considering that other discounts are still applicable (up to 98% for micro-enterprises), today the entry level for development investments is quite low.

Speaking of discounts – the 95% discount that used to apply to new investments by medium and large enterprises into modern business services now will apply if modern business services are the main function of the enterprise. Previously, modern business services had to be the only function of the enterprise. At present, this means a medium-sized entrepreneur may ask for support, such as some new IT investment, and a 95% discount will be granted even if there is some other activity possible.

Though consistently limited, the PIZ remains the most efficient instrument of tax support for development. Besides the PIZ, taxpayers are allowed additional deductions like the R&D allowance, robots allowance, test production and prototypes or CSR allowance. These however, in principle, cannot be combined with the PIZ exemption.

more across site & shared bottom lb ros

More from across our site

The surge in probes comes as the UK tax authority seeks to close a VAT gap of £11.4bn from last year, Pinsent Masons’ research has suggested
ITR’s survey data reveals widespread client disappointment with firms’ use of technology but our upcoming AI in Tax event offers advisers a chance to flip the script
Firms announced key tax partner hires across the US and UK, while fintech and software providers revealed board appointments and new tools for multinational tax teams
It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
Gift this article