The expiry of SEZ permits in Poland at the end of 2026 will be one of the most important tax changes for companies that have benefited for years from income tax exemption based on permits to operate in Polish Special Economic Zones (SEZs). From 2027, companies operating solely on the basis of such permits will no longer be able to settle tax-exempt income under this model. In practice, this means the need to prepare for higher tax burdens, a different approach to calculating taxable results and a reassessment of available investment support instruments in Poland.
This change does not mean that companies must cease operations in their existing locations. Nor does it automatically mean the loss of access to all forms of tax preference. What is coming to an end is the possibility of using income tax exemption based on SEZ permits connected with the historical system of Polish Special Economic Zones.
For manufacturing, logistics and service companies, including foreign investors operating in Poland, 2026 should be a time for a detailed review of tax settlements, public aid limits and investment plans for the coming years.
What does the expiry of SEZ permits in Poland mean?
For many years, Special Economic Zones were one of the key instruments supporting investment in Poland. Companies that obtained a permit to operate in an SEZ could benefit from income tax exemption within the granted public aid limit. The exemption applied to income generated from activities carried out within the zone and covered by the scope of the permit.
At the end of 2026, the period of validity of SEZ permits expires. This means that after 31 December 2026, a taxpayer will no longer be able to use the tax exemption on the basis of such a permit, even if the full available public aid limit has not been used.
Key Deadline
2026
Review period
Verify permit conditions, used aid limits and accounting records
2026
Deadline Year
Last opportunity to use remaining public aid limit and organise documentation
31 Dec 2026
Hard Cutoff
SEZ permits expire. Exemption no longer available on this basis
2027+
New Regime
Full taxation unless a valid decision on support or relief applies
Shifted tax year? If your tax year spans the 31 December 2026 boundary, you must determine the result attributable to each period separately — before the year ends, not after.
In practice, the three most important consequences are as follows:
- income that was previously covered by the SEZ tax exemption will generally become taxable;
- the unused part of the public aid limit under the SEZ permit will no longer be available after the permit expires;
- the company will need to adjust its accounting, tax and controlling model to the new settlement rules.
The end of 2026 should therefore not be treated merely as a formal administrative date. For many companies, it will mark the transition from a model in which part of their income was tax-exempt to a model based on full taxation or on new forms of support, such as a decision on support under the Polish Investment Zone.
How should companies settle income until the end of 2026?
Until the end of 2026, companies using SEZ permits should continue to settle tax-exempt and taxable income in line with the existing rules. The key issue is to correctly determine which part of the tax result comes from activities covered by the permit and which part comes from activities outside the scope of the exemption.
In practice, this requires maintaining records that make it possible to separate:
- revenue from activities covered by the SEZ permit;
- costs allocated to tax-exempt activities;
- revenue and costs related to taxable activities;
- common costs and the rules for their allocation;
- the used and remaining public aid limit.
The closer companies get to the end of 2026, the more important the quality of accounting and tax data will become. Errors in the allocation of revenue or costs may result in incorrect calculation of tax-exempt income and, consequently, tax risk.
For companies that have operated for many years under a stable SEZ model, the expiry of permits may require changes to internal procedures. This concerns not only tax and accounting departments, but also finance teams, investment teams and management boards responsible for cash flow planning.
What will change in tax settlement from 2027?
From 2027, a company that held only an SEZ permit and has no other active basis for tax exemption will recognise income from its former SEZ activity as taxable income. This means that the distinction between tax-exempt and taxable results will no longer be relevant for the current exemption arising from the SEZ permit.
Business Impact
01
Income tax payable
Previously exempt SEZ income will be subject to standard corporate income tax — directly increasing the tax liability.
02
Effective tax rate rises
The effective tax rate may increase once the exempt income portion disappears. Financial models built on the SEZ rate will be materially incorrect from 2027.
03
Investment profitability
Projects assessed under the SEZ model will show lower after-tax returns. Group HQ should be informed if Polish results affect group-level planning or IRR calculations.
04
Cash flow forecasts
Higher tax payments reduce distributable cash. Treasury and dividend planning for 2027–2029 must account for the additional liability.
05
Transfer pricing policy
Intra-group arrangements designed to maximise income in the exempt Polish entity may need restructuring once the exemption disappears.
06
2027–2029 budgets
Annual plans, CAPEX models and cost-of-operation assumptions for Polish entities must be revised before board approval cycles begin.
This change may directly affect:
- the amount of income tax payable;
- the effective tax rate;
- the profitability of investment projects;
- cash flows;
- transfer pricing policy within capital groups;
- budgets for 2027 and subsequent years.
For foreign companies operating in Poland, it may be particularly important to present the impact of this change to the group’s headquarters in advance. In many organisations, financial models, investment plans and tax forecasts are prepared well ahead of time. If the profitability of the Polish company has so far been partly based on SEZ tax exemption, the end of this exemption should be reflected in financial planning.
It should also be remembered that the expiry of SEZ permits does not automatically close previous documentation obligations. The company should continue to hold documentation confirming the correctness of earlier settlements, including data on eligible costs incurred, tax-exempt income, public aid used and fulfilment of the permit conditions.
Unused public aid – what should be verified before the end of 2026?
One of the most important issues connected with the expiry of SEZ permits in Poland is unused public aid. In practice, this refers to the part of the tax exemption limit that the company did not manage to use during the validity period of the permit.
It should be emphasised that unused public aid is not an amount that can be recovered in cash. It is an unused limit of tax preference. The ability to use it depends mainly on whether the company generates income eligible for exemption by the end of 2026 and whether it meets all conditions resulting from the permit and public aid regulations.
Companies should therefore establish:
- the maximum public aid limit resulting from the investment;
- how much of this limit has already been used;
- how much of the limit remains unused;
- whether projected income by the end of 2026 allows the remaining limit to be used;
- whether there are any operational or organisational measures that may help use the available preference correctly;
- whether tax records allow the company to safely demonstrate tax-exempt income.
Particular caution is needed in this area. Not every change in the operating model will be permitted or tax-neutral. Measures taken before the end of 2026 should have a business justification and comply with the terms of the SEZ permit, public aid settlement rules and general Polish tax regulations.
Shifted tax year and the expiry of SEZ permits in Poland
Companies whose tax year does not correspond to the calendar year require particular analysis. If the tax year covers both the period until 31 December 2026 and the period after that date, the tax consequences for both parts of the period will need to be determined precisely.
The practical issue is that the SEZ permit ceases to provide a basis for exemption after 31 December 2026, while the taxpayer’s tax year may end later. In such a situation, the company should prepare in advance a method for determining the result attributable to the period during which the permit was still valid and the result attributable to the period after its expiry.
In practice, this may require:
- preparing additional accounting statements;
- establishing rules for allocating revenue and costs to the relevant periods;
- analysing common costs;
- verifying the settlement of tax-exempt income for the final period of using the exemption;
- agreeing the approach with tax advisers or auditors.
This issue should be analysed in advance. Attempting to reconstruct data only after the end of the tax year may be time-consuming and carry a higher risk of error.
What about companies that also have a decision on support?
Some companies hold not only a historical SEZ permit, but also a decision on support issued under the Polish Investment Zone. In such cases, the expiry of the SEZ permit does not necessarily mean the complete end of the tax exemption. However, it is essential to correctly determine the legal basis of the preference and the income to which it applies.
A decision on support is not a simple extension of an SEZ permit. It is a separate instrument connected with a new investment and specific conditions. Tax exemption based on a decision on support applies to income from business activity specified in that decision and conducted in the location indicated in it, taking into account the conditions of the decision and the available public aid limit. In practice, the scope of tax-exempt income should always be analysed in relation to the specific decision, investment and operating model.
A company holding both an SEZ permit and a decision on support should analyse:
- which income has so far been settled on the basis of the SEZ permit;
- which income may be covered by the decision on support;
- whether the scope of activity in both documents is the same, similar or different;
- how costs and revenue should be allocated to individual sources of exemption;
- what part of public aid has already been used;
- whether tax records will need to be modified from 2027.
It cannot be assumed that from 2027 all previously exempt SEZ income will automatically be exempt under the decision on support. Each decision requires individual analysis, as its scope depends on the conditions specified in the document and the actual way in which the business is conducted.
Polish Investment Zone as a new direction of support
For companies that want to continue using tax preferences after the expiry of SEZ permits, the Polish Investment Zone is a natural area for analysis. This mechanism allows companies to obtain income tax exemption on the basis of a decision on support, but it requires a new investment and fulfilment of specific criteria.
The Polish Investment Zone differs from the earlier SEZ model. Support is not limited only to areas covered by a Special Economic Zone. It may be granted for investments implemented in various locations across Poland, provided that the statutory conditions are met.
A decision on support specifies, among other things:
- the period for which the preference applies;
- the location of the investment;
- the scope of business activity;
- conditions relating to eligible costs or employment;
- qualitative criteria that the company undertakes to meet;
- the maximum level of available public aid.
For a foreign investor, a decision on support may be an important element of planning further projects in Poland. However, it should not be treated as an automatic replacement for an expiring SEZ permit. The key issue is whether the company is planning a new investment that may qualify for support.
More information on this topic: Polish Investment Zone – planned changes and their importance for investors.
Tax reliefs after the end of the SEZ exemption
After the Exemption
Decision on Support — Polish Investment Zone
A separate instrument tied to a new investment in a specific location. Not an automatic extension of an SEZ permit. Requires new eligibility analysis and fulfilment of qualitative and quantitative criteria.
Research & Development Tax Relief
Additional deduction of eligible R&D costs. Activity must be creative, systematic and aimed at increasing knowledge — not every process improvement qualifies.
IP Box
5% preferential rate on income from qualifying intellectual property rights. Requires a nexus between R&D expenditure and the IP generating the income.
Investment Grants & EU Subsidies
Non-repayable national and EU-funded programmes for manufacturing, energy transformation and innovation. Project-specific — not a general offset against tax liability.
The expiry of SEZ permits may cause companies to place greater emphasis on other instruments that reduce their effective tax burden in Poland. This applies especially to manufacturing, technology and research and development companies that incur significant expenditure on development, automation or innovation.
One of the most important solutions may be the research and development tax relief. It allows an additional deduction of certain eligible costs related to R&D activities. However, not every improvement of a production process or implementation of a new solution will automatically qualify as research and development activity. It is necessary to analyse whether the activities are creative, carried out systematically and aimed at increasing knowledge resources or using knowledge to create new applications.
For some companies, the robotisation tax relief may also be relevant, but it should be remembered that this is currently a temporary solution. The deduction applies to costs incurred from the beginning of the tax year starting in 2022 until the end of the tax year starting in 2026. Therefore, in the context of expiring SEZ permits, this relief should primarily be analysed as an instrument requiring verification before the end of 2026, rather than as a standard solution available after 2026.
After the end of the SEZ exemption, companies may also consider other instruments, such as:
- IP Box;
- investment grants;
- national and EU subsidies;
- support for energy transformation;
- instruments for innovative projects;
- preferences related to employment and training.
These are not simple substitutes for the SEZ exemption. Each instrument has different conditions, limits, documentation requirements and tax consequences. Therefore, a review of available tax reliefs and grants should be part of a broader tax and investment strategy, rather than an action taken only at the end of the year.
Impact on budgets and financial planning
For many companies, the end of the SEZ exemption will have a measurable impact on net financial results. If a company has for years treated a significant part of its income as tax-exempt, from 2027 its effective tax burden may increase.
For this reason, companies should prepare a tax forecast for 2027–2029. Such an analysis should show how the company’s position may change under different scenarios, for example:
- without a new decision on support;
- with a new decision on support for another investment;
- with the use of tax reliefs;
- with an obtained subsidy or grant;
- with a change in profitability levels;
- with a change in the cost structure.
This type of model may be particularly important for foreign investors that report the results of their Polish company to a capital group. Higher taxation may affect not only the local budget, but also the assessment of investment profitability in Poland, dividend policy and decisions concerning future projects.
Risk of tax audits after the exemption period ends
The expiry of SEZ permits does not mean that previous settlements will no longer matter. Polish tax authorities may verify whether the exemption was used correctly in the years in which the company settled SEZ income. Companies should therefore ensure that their documentation is complete and their data consistent.
Particular importance may be attached to:
- the content of the SEZ permit;
- documentation of investment expenditure incurred;
- records of eligible costs;
- calculation of public aid used;
- the method of determining tax-exempt income;
- allocation of common costs;
- transfer pricing documentation;
- confirmation that the permit conditions were fulfilled.
From a tax security perspective, 2026 should be used not only to maximise the use of the available public aid limit, but also to organise documentation. This is particularly important for companies that have conducted SEZ activities for many years, changed the scope of production, developed new business lines or undergone reorganisations.
Checklist before the end of 2026
Companies using SEZ permits should treat the end of 2026 as a key deadline for organising tax settlements and planning the next stage of business activity in Poland. The most important actions include the following:
1. Verify the conditions of the SEZ permit
The company should check the scope of activity covered by the permit, investment conditions, employment obligations and the period during which the exemption may be used.
2. Determine the used public aid limit
The company should calculate what part of the available limit has already been used and what amount remains available until the end of 2026.
3. Prepare a forecast of tax-exempt income
The company should estimate whether it will generate income by the end of 2026 that allows the remaining public aid limit to be used.
4. Review accounting and tax records
It is necessary to check whether accounting data makes it possible to correctly separate tax-exempt and taxable results.
5. Analyse the consequences for companies with a shifted tax year
Taxpayers whose tax year does not correspond to the calendar year should carefully plan the settlement of the period covering the turn of 2026 and 2027.
6. Verify existing decisions on support
If the company has a decision on support, it should verify which income may be covered by the exemption after 2026 and how records should be maintained.
7. Assess the possibility of obtaining a new decision on support
If the company plans another investment in Poland, it is worth analysing whether the project may qualify for support under the Polish Investment Zone.
8. Review tax reliefs and grants
The company should check whether, after the end of the SEZ exemption, it may benefit from R&D tax relief, robotisation tax relief, IP Box, grants or other forms of support.
9. Update budgets and financial models
The increase in taxation from 2027 should be reflected in budgets, cash flow forecasts and investment plans.
10. Organise documentation in case of a tax audit
The company should secure documents confirming the correctness of SEZ settlements for previous years.
Summary
The expiry of SEZ permits in Poland at the end of 2026 represents a significant change for companies that have benefited for years from tax exemption in Special Economic Zones. From 2027, income from activities previously covered by an SEZ permit will generally be taxable, unless the company has another basis for preference, such as a decision on support under the Polish Investment Zone.
The most important task for 2026 is to determine whether the company will use the available public aid limit, how it should settle the final period of validity of the permit and which instruments may support its activity after 2026. In many cases, this will require a review of accounting records, tax documentation, investment plans and available tax reliefs. A well-prepared company can reduce tax risk, plan its tax burden from 2027 more effectively and make an informed decision on whether future investments in Poland should be covered by a new decision on support, tax reliefs or other forms of public aid.
