Payment of profit from Poland abroad in 2026
Transfer of funds from JDG, dividend from the company, WHT, certificate of residence, pay and refund and transfer prices.
The mere transfer of funds abroad is not a separate tax. The effects depend on the source of the money: a JDG owner's payout, a dividend, a salary, a loan and a royalty are different events.
Funds of the JDG owner
JDG is not a separate legal entity. After correct settlement of income, tax and contributions, the owner can transfer his funds to a foreign account without "transfer tax".
This does not change tax residence or the rules for taxing foreign income. The bank may require documents based on AML regulations.
Dividend from a Polish company
The Polish company settles CIT, and dividend payments are generally subject to 19% withholding tax. A double taxation avoidance agreement or EU exemption may reduce the tax, but requires meeting conditions.
A residency certificate does not automatically give you any reduced rate. The payer must exercise due diligence, check the actual owner, the content of the specific contract and the conditions of release.
For certain payments to related entities exceeding PLN 2 million per year, the pay and refund mechanism may operate. The scope of this mechanism does not cover every foreign payment.
Dividend exemption in the EU
The exemption can operate between qualifying EU or EEA companies with at least 10% ownership held continuously for two years and other conditions being met. In certain situations, the period may expire after payment, but failure to meet it results in the obligation to pay with interest.
Service or loan instead of dividend
The invoice to the affiliate must document actual service at market price. It is not a simpler substitute for a dividend if the benefit does not exist.A loan to a shareholder requires an agreement, market conditions and an analysis of CIT, PCC, transfer prices and provisions on hidden profits if the company applies Estonian CIT.
Transfer prices
Documentation thresholds depend on the type of controlled transaction. As a rule, they amount to, among others, PLN 10 million for commodity and financial transactions and PLN 2 million for service and other transactions, with separate rules for tax havens.
The general table "2 million for goods and 500,000 for services" does not apply. The TPR obligation, benchmarking and deadlines need to be checked for a specific year.
Sources
Are you planning a cross-border withdrawal?
This is a topic for a tax advisor and a lawyer before the transfer. Oxyok provides ongoing accounting for Polish JDGs - from PLN 49 + VAT per month.