Repatriation of Profits from Poland 2026
Repatriation of profits from Poland in 2026. Dividends, transfers, withholding tax (WHT), double taxation treaties. A guide for foreign entrepreneurs.
If you are a foreigner doing business in Poland, sooner or later the question arises: how do you transfer profits to your home country? This process is called repatriation and it has tax consequences.
In this guide, I explain how the repatriation of profits from Poland works in 2026.
Profit repatriation — WHT 19%, MDF directive, double tax treaties
Dividend payments to foreign shareholders are subject to withholding tax (WHT) of 19%. The Mother-Daughter Directive (MDF) can reduce the rate to 0%. Double tax treaties (DTT) can lower WHT to 5–15%.
The standard withholding tax rate on dividends paid to foreign entities. The Polish payer deducts the tax at the time of payment.
WHT exemption for dividends paid to a parent company from another EU country when the holding is at least 10% for a minimum of 2 years. Requires a tax residency certificate.
International treaties can reduce the WHT rate below 19%. The rate depends on the recipient country and the percentage of shares held.
WHT rates under treaties (examples)
| Recipient country | Domestic rate | Treaty rate |
|---|---|---|
| 🇳🇱 Holandia / Netherlands | 19% | 0% (MDF) / 5% |
| 🇩🇪 Niemcy / Deutschland | 19% | 0% (MDF) / 5% |
| 🇫🇷 Francja / France | 19% | 0% (MDF) / 5% |
| 🇬🇧 UK / Wielka Brytania | 19% | 5% / 10% |
| 🇺🇸 USA / Stany Zjednoczone | 19% | 5% / 15% |
| 🇨🇿 Czechy / Česko | 19% | 0% (MDF) / 5% |
Transactions between related parties must be conducted at arm’s length. TP documentation is mandatory above 2 million zł (tangible/financial transactions) or 2 million zł (services).
Important: The MDF exemption or treaty rates require a declaration and tax residency certificate before payment. No certificate = 19% deduction. Pay and refund is not available for dividends. Transfer pricing: a TP study audit is mandatory for cross-border transactions above the thresholds.
Planning a dividend payout abroad? Let’s review your options.
Let's check →WHT rate 19%: Art. 21(1)(49) of the CIT Act. MDF directive: Art. 21(3). Double taxation treaties take precedence over domestic law. Rates may change. Transfer pricing: Art. 11a et seq. of the CIT Act.
Forms of Profit Transfer
1. Dividend from a limited liability company (spółka z o.o.)
If you are a shareholder in a Polish spółka z o.o. (limited liability company):
- The company pays corporate income tax (CIT — corporate income tax) at 9% or 19% on its profit
- The dividend paid to the shareholder is subject to withholding tax (WHT — withholding tax)
- WHT rate: 19% (standard) or lower under a double taxation treaty
2. Service fees (B2B)
If you run a sole proprietorship (JDG) and issue invoices to related foreign entities:
- Revenue is taxed in Poland (lump-sum tax / tax scale / flat tax)
- Transfer via a B2B invoice is simpler than a dividend
- But the tax office (US) may examine whether transfer prices are at arm's length
3. Loan to a shareholder
- The company can grant a loan to a shareholder (instead of a dividend)
- Terms must be at arm's length (interest rate, term)
- No tax on principal repayment
4. Profit from a sole proprietorship (JDG)
If you run a JDG (not a company):
- Revenue is taxed in Poland
- After paying tax — you may freely transfer funds abroad
- No additional tax on the transfer
Withholding tax (WHT) on dividends
Standard rate: 19%
Poland levies 19% withholding tax (WHT) on dividends paid to non-residents.
Rates under double taxation treaties
Treaties can reduce WHT:
| Recipient country | Treaty WHT rate | |-------------------|-----------------| | Germany | 15% (5% if >25% of shares) | | France | 15% (5% if >25% of shares) | | United Kingdom | 15% (5% if >25% of shares) | | Netherlands | 15% (5% if >10% of shares) | | USA | 15% (5% if >25% of shares) | | Ireland | 15% (5% if >25% of shares) |
How to benefit from a lower rate?
- Certificate of residence — the shareholder submits a tax residence certificate from their home country
- Application to the tax office (US) — before the dividend payment
- The company applies the reduced rate — based on the certificate
Mother-Daughter Directive (MAT)
If the shareholder is an EU company (holding at least 10% of shares for 2 years):
- 0% WHT — exemption from withholding tax
- Conditions: parent company status, minimum 10% holding, 2-year period
Transfer Pricing
If you have transactions with related foreign entities:
Transfer pricing documentation
- Transactions above 2 million zł (goods) or 500,000 zł (services) — documentation required
- You must prove that prices are at arm's length
- Form: TPR (Transfer Pricing Report)
Types of transactions:
- Sale of goods to a related entity
- Services between related entities
- Loans, licenses, fees
Penalties for missing documentation:
- 10,000 zł for missing local documentation
- Additional penalties for irregularities
FAQ
Do I have to pay tax on transferring money from a JDG abroad?
No. If you run a JDG and have paid income tax in Poland — you may freely transfer funds. There is no additional transfer tax.
Is a dividend from a Polish company to Germany taxed?
Yes. WHT rate: 15% (or 5% if you hold at least 25% of shares). With a residence certificate — reduced rate.
Can an EU company receive a dividend at 0% WHT?
Yes, if the conditions of the Mother-Daughter Directive are met (EU parent company, min. 10% holding, 2 years).
Does transfer pricing apply to small companies?
Yes, if transactions with related entities exceed 2 million zł (goods) or 500,000 zł (services).
Need Help?
I provide accounting for foreigners — profit repatriation, WHT, transfer pricing, dividends. From 149 zł + VAT per month.
Reply to [email protected] or visit oxyok.com/en.
Note: Profit repatriation: dividend 19% WHT (lower with a treaty), JDG with no additional transfer tax. Transfer pricing above the threshold requires documentation. Before making a decision, consult an accountant.
Questions about accounting?
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