Polish Government Tightens Tax Rules for Family Foundations and Raises CIT on Banks

The Polish government has approved two legislative proposals that tighten tax rules for family foundations and raise corporate income tax (CIT) rates for banks, while at the same time reducing the so-called bank tax. The new measures, adopted by the Council of Ministers, are intended both to close loopholes in the Family Foundation Act and to increase state revenues in the coming years.

The first draft law amends the Corporate Income Tax Act with the aim of addressing ways in which family foundations have been used for tax optimisation. According to the government, some entities have been exploiting the legal framework for purposes inconsistent with the original intent of supporting succession planning and wealth management for families. The changes include taxing income from property sales carried out within 36 months of being contributed to a foundation, taxing income earned through tax-transparent entities, and applying controlled foreign company (CFC) rules and exit tax provisions to foundations. Income from short-term rental agreements will also be taxed, and the definition of so-called hidden profits will be broadened to cover cases where loans to founders, beneficiaries, or related persons are repaid by the foundation.

The second proposal amends both the Corporate Income Tax Act and the Act on Tax on Certain Financial Institutions. It introduces a sharp increase in CIT rates for banks, rising from the current 19 percent to 30 percent in 2026, then gradually decreasing to 26 percent in 2027 and 23 percent from 2028 onwards. Banks that currently benefit from the preferential 9 percent rate will also see increases, with their CIT raised to 20 percent in 2026, 16 percent in 2027 and 13 percent from 2028. At the same time, the bank tax – currently set at 0.0366 percent of the tax base – will be reduced to 0.0329 percent in 2027 and 0.0293 percent from 2028.

The Ministry of Finance estimates that the measures will boost state revenues by approximately PLN 6.6 billion in 2026 and PLN 4.7 billion in 2027. The new tax rules are scheduled to take effect on January 1, 2026.

The government argues that the tightening of tax provisions will ensure greater fairness and close gaps in the system, particularly for family foundations. For the banking sector, the higher CIT rates are expected to be partly offset by the reduction in the bank tax, though the overall effect will increase budget revenues. The changes mark one of the most significant shifts in Poland’s tax landscape in recent years, reflecting both fiscal consolidation efforts and a response to evolving financial practices.