Enhanced tax exemptions for holding companies in Poland
With 2023 comes numerous changes to improve the availability and operation of the Polish holding company model.
It is worth remembering that the capital gains tax exemption for holding companies was introduced into Polish tax law under the so-called Polish holding model as of January 1, 2022. It has already been subject to significant amendments, which are primarily designed to mitigate the effect of certain obstacles and enhance the regulations, and take effect from January 1 2023.
The PHC model is based on two key corporate income tax (CIT) exemptions:
- A dividend tax exemption – starting from January 1 2023, dividends received from Polish or foreign subsidiaries by a PHC will be 100% CIT exempt (in 2022, the exemption covers 95% of a dividend)
and
- A capital gains tax exemption – the profit from a qualifying disposal of shares in a Polish or foreign subsidiary to a non-related party is exempt from the 19% CIT normally applicable to capital gains.
More on the subject can be read in the article by Magdalena Zamoyska and Monika Grobelska at: