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Income tax on controlled foreign corporations

by Agnieszka Gliwińska

21 September 2023

We are writing to remind you about the upcoming deadline for clearing the income tax on controlled foreign corporations (CFC) for 2022.

The CIT-CFC filing deadline expires on 2 October 2023.

Who is obliged to pay this tax?

The tax is payable by a Polish company which exercised control over a foreign entity in 2022 either by capital links (shares, right to profit) or by actually managing that entity.

The tax is levied on income of foreign entities established or managed in a tax heaven or a country with which Poland has not signed a tax treaty or a tax information exchange agreement.

The tax is also levied on income of foreign entities from other countries, including those established in the European Union, which offer lower taxation rates than Poland if they disclose broadly-understood passive revenues (including revenues from intangible services) or have certain significant assets and earn little revenue, or show high profitability.

What entity can be a CFC?

Foreign controlled corporations may be e.g.:

legal persons, including incorporated companies,
companies pending incorporation,
partnerships subject to income tax in their country of establishment,
foundations, trusts,
tax-consolidated groups or their members,
foreign branch offices, establishments of foreign entities.

If you have further questions about the income tax on controlled foreign corporations, you are welcome to contact us.

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Agnieszka Gliwińska

Tax adviser (Poland)

Senior Associate

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