Poland is planning significant changes to the Polish Investment Zone (PIZ) regime, one of the key tax incentives available to companies investing in Poland.
The PIZ allows companies carrying out new investments in Poland to benefit from income tax exemption. In practice, it may significantly reduce the effective tax burden on profits generated from eligible investment activity.
The draft amendment was published in June 2026. It is intended to adapt the regime to the expiry of the old Special Economic Zones system at the end of 2026. It should also simplify the use of the exemption and make the regime more suitable for reinvestments, automation and large industrial projects.
How PIZ works
The PIZ is a tax exemption granted on the basis of a decision on support. The amount of available aid depends mainly on:
- the value of eligible costs,
• the regional aid intensity applicable to the investment location,
• the size of the investor.
Eligible costs may generally include capital expenditure, such as the acquisition of land, buildings, machinery, equipment and certain intangible assets, or two-year labour costs of newly created jobs. For large enterprises, certain limits apply, including to intangible assets. The support is also subject to sectoral exclusions and quantitative and qualitative criteria.
The maximum amount of tax exemption is calculated as:
eligible costs x regional aid intensity
Regional aid intensity depends on the investment location and size of the company (it is increased by 10 percentage points for medium-sized enterprises and by 20 percentage points for small and micro enterprises). Under current rules, a decision on support is generally issued for 12, 14 or 15 years, depending mainly on the location and aid intensity. PAIH provides a useful practical summary of the current regime here.
What is expected to change?
The draft amendment introduces several important changes.
First, decisions on support would be issued for a longer period: from 15 to 20 years. This should make the incentive more attractive for large, capital-intensive projects, where the available aid limit may be difficult to use within a shorter period.
Second, the rules for determining exempt income should be simplified. Today, reinvestments often raise a practical question: can the exemption cover income from an existing plant if the new investment is closely linked to existing assets? This has led to disputes around the so-called “close links” concept.
The draft moves away from this approach. In general, the exemption should depend more on the activity and location specified in the decision on support, and less on proving links between the new and existing assets.
Third, the draft introduces an opinion of the Head of the National Revenue Administration. For projects where the maximum amount of public aid is at least PLN 25 million, such an opinion would be mandatory before the decision on support is issued. For smaller projects, the opinion may become optional, although during the initial transitional period it is expected to apply only to larger projects.
The opinion would focus mainly on whether the description of the supported activity and the investment location are complete, clear, consistent and correct for tax exemption purposes.
This may increase tax certainty. However, it may also add a new procedural stage and require investors to prepare the investment description more carefully from the very beginning.
Fourth, the draft removes the job creation requirement for investments in robotisation and automation involving the purchase of industrial robots. This is a welcome change, as modern industrial projects often focus on productivity, automation and maintaining production capacity rather than increasing headcount.
Fifth, the procedure should become more digital. A new electronic platform for PIZ is planned. Applications, correspondence and deliveries would eventually be handled through the system.
When would the changes apply?
Most of the changes are expected to enter into force on 1 January 2027.
The electronic platform rules are expected to apply later, from 1 July 2028.
Some tax changes are intended to apply to income generated from 1 January 2022. This retroactive element should be reviewed carefully by companies already benefiting from decisions on support.
Why does it matter?
The reform is important for both new investors and companies already operating in Poland.
For new investors, the Polish Investment Zone may become more attractive because of the longer support period and potentially broader and clearer rules for exempt income.
For existing investors, especially manufacturing companies planning reinvestments in Polish plants, the reform may make it easier to apply the exemption to income generated by integrated production activity.
For large international groups, however, the new rules also mean that the application stage will become more important. The description of the investment, business activity, PKWiU classification, location and accounting separation may have a direct impact on the tax benefit available in future years.
Who should pay attention?
The changes should be particularly relevant for:
- foreign groups with manufacturing companies in Poland,
• investors planning new production facilities or expansion projects,
• companies considering automation or robotisation projects,
• businesses already using Polish Investment Zone support,
• groups modelling the effective tax rate of Polish operations,
• companies with several decisions on support or several activities carried out in one location.
How we can help
ABC Tax can support investors at each stage of the Polish Investment Zone process.
In particular, we can help with:
- assessing whether a planned investment may qualify for support,
• estimating the potential value of the CIT exemption,
• reviewing eligible costs and aid intensity,
• preparing or reviewing the tax assumptions for the application,
• analysing the impact of the planned reform on existing decisions on support,
• verifying the scope of exempt income,
• reviewing accounting separation and transfer pricing implications,
• supporting discussions with zone authorities and tax authorities.
The Polish Investment Zone may remain one of the most attractive tax incentives for investors in Poland. The planned reform should make the regime more flexible, but it will also require careful tax and procedural preparation.
Contact us about Polish Investment Zone