The Polish government is preparing changes that could make it significantly easier for entrepreneurs operating in Special Economic Zones (SEZ) and the Polish Investment Zone (PIZ). The draft amendment to tax regulations has just been made public. What exactly is set to change, and why should you pay attention — particularly if you run or are planning to start a business in Poland, especially in the investment zones?
Tax amendment in investment zones in Poland – no more penalties greater than the aid received
Until now, the regulations stipulated that if an entrepreneur had their support decision (i.e. income tax exemption) revoked, they had to repay not only the value of the exemption but often much more – in practice, the entire tax on the income earned from the supported activity. For many companies, this meant financial disaster. This interpretation led to situations where the penalty was disproportionate to the scale of the offence – sometimes a formal error was enough to lose support and face severe consequences.
Changes to regulations – what do investors in investment zones in Poland gain?
The amendment introduces a fairer approach. An entrepreneur who has had their support decision revoked will not have to pay back more than the actual value of the tax exemption they benefited from. In practice, this means they will no longer face a tax bill several times higher than the aid received. The condition, however, is that the income must be properly documented in the accounting books.
Importantly, the changes will also apply to decisions issued before the amendment comes into force, if they are revoked after 31 December 2025. This is crucial for investors already operating in the Polish market.
Reduced administrative burden for companies in Poland
The project is part of a broader 2025 plan for deregulation and economic simplification. In addition to changes in the rules for settling aid, the Ministry of Finance wants to reduce administrative obligations. For example, general partnerships will no longer have to submit annual information on partners if the partnership agreement remains unchanged. This means a real saving in time and paperwork for companies.
Greater flexibility for capital groups
Another favourable change concerns Polish tax capital groups (PGK). Currently, concluding even a single transaction with a related party on “non-market terms” can result in the loss of CIT taxpayer status. This sanction will be abolished under the new rules – the government recognises that determining what constitutes a “market price” is complex and interpretational differences can occur despite due diligence.
Poland more attractive for foreign investors
For foreign investors considering investments in Poland – particularly within special zones – this is a very positive signal. The new regulations increase transparency, predictability, and reduce tax risks. Lower risk means higher investment attractiveness. Poland is becoming not only cost-competitive but also increasingly business-friendly.
In short: the new regulations mean less bureaucracy, greater tax security, and real relief for businesses operating in zones. This is also proof that Poland listens to the voice of entrepreneurs – both domestic and foreign. Are you planning to invest in Poland? Now is truly a good time.
