Polish "Estonian CIT"

[inector]

To benefit from 0% tax until distribution, you need to hire 3 employees, that's fine, but...

the requirement to employ at least three individuals under an employment contract or other civil law contract, subject to PIT and social security contributions
Click to expand...

They never mention if employees have to be in Poland...

Can't you employ someone from abroad (from like Spain), pay employer social contributions in Poland, yet still benefit from 0% tax?

 

[Marzio]

Of course they need to be Polish employees, what would be the point otherwise?

 

[Sols]

I would be surprised if that was the intention of the Polish law. Expect pushback‌ from the tax authority if you try to pull that.

On the other hand, you‍ could maybe pull some EU single market argument. If the Polish tax authority declines that,⁠ you'd have to go to court and possibly appeal to European courts.

 

[Marzio]

If he has a lot of‍ time and money to waste that could be a route.

if you want to avoid⁠ any problems hire in Poland.

If you don't want to hire in Poland don't use⁤ Estonian CIT

 

[inector]

Well said, thank you Marzio and Sols