Updates · 7 October 2026
Notional Interest: An Additional Tax Deduction for Retained Profits and Shareholder Contributions
Companies subject to CIT, including incorporated companies and partnerships taxed under CIT such as limited partnerships, may claim an additional tax deduction where they finance their business with equity, namely retained profits or additional shareholder contributions. This is known as notional interest under Article 15cb of the CIT Act.
The mechanism reduces tax without an actual expense being incurred and can also be applied to previous years.
01
How the Mechanism Works
The deductible amount is the National Bank of Poland reference rate plus one percentage point, multiplied by the retained profit or additional contribution.
The deduction is available for three years, up to PLN 250,000 per year — total tax savings may therefore reach approximately PLN 142,500.
02
Claims for Previous Years
Companies that have not used the mechanism may claim the deduction retrospectively by amending CIT-8 returns for years that are not time-barred.
It is worth acting promptly: the 2020 return can only be amended until the end of 2026.
03
Key Conditions
- Keeping the Funds for Three Years — distributing the profits or repaying the contribution earlier reverses the deduction.
- Economic Justification — retaining the profits should serve a genuine business purpose.
We will be happy to check whether your company can use this mechanism and estimate the potential savings. Please contact us.
This information does not constitute a legal opinion. For further information or legal assistance, please contact our firm: 42 207 66 66, kancelaria@krs-adwokaci.pl.
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Do You Have Questions about This Topic?
We will be happy to explain what these changes mean for your business and which steps you may wish to take. Get in Touch — by telephone or email.