Poland Proposes More Attractive Tax Incentives

Businesses investing in manufacturing capacity, industrial robotics and automation in Poland could soon benefit from more favourable tax rules. Two bills amending the Corporate Income Tax (CIT) Act, submitted to the President for signature on 28 October 2026, propose extending the robotization tax relief, broadening access to the Polish Investment Zone (PSI) exemption and giving investors more time to benefit from available tax incentives.

The proposed changes could provide meaningful support for businesses planning new investments, expanding existing production facilities or automating their operations in Poland.

Neither bill has been signed into law yet. The President has 21 days from submission to make a decision, meaning the deadline is 18 November 2026. The bills have not faced opposition from opposition parties and are therefore expected to be signed. Most of the proposed changes are scheduled to take effect on 1 January 2027.

For businesses considering investment decisions, it is worth understanding the proposed changes now.

1. Robotization Tax Relief Extended Until 2036

Businesses investing in industrial robots and automation could benefit from an additional tax deduction for another 10 years. Introduced to encourage the adoption of robotics in Polish businesses, the robotization tax relief currently allows companies to deduct an additional 50% of eligible robotization expenditure from their tax base.

Eligible costs go beyond the purchase of industrial robots themselves. They may also include software, training services and peripheral equipment used with industrial robots, such as guide rails.

Under the current rules, the relief applies to eligible costs incurred up to the end of the tax year beginning in 2026. The proposed amendment would extend its availability until the end of the tax year beginning in 2036.

The bill also addresses a long-standing dispute over how the relief should be accounted for in relation to fixed assets. While administrative courts have previously accepted a one-off deduction, the proposed rules would require the additional deduction to be claimed gradually through depreciation charges.

What this means for businesses: Companies planning to invest in industrial robotics and automation would have a much longer period in which to benefit from the relief. This could be particularly relevant when planning multi-year investment programmes and assessing the tax impact of automation projects.

2. PSI Exemption Made More Accessible

Expanding or modernising an existing plant could become more tax-efficient, with a broader range of income potentially qualifying for the PSI exemption. The Polish Investment Zone (PSI) regime allows businesses to benefit from a corporate income tax exemption on income generated by activities covered by a support decision, subject to the applicable public aid limit.

The amount of available aid depends, among other factors, on the eligible investment costs and the location of the investment.

Under the current rules, when a new investment increases the production capacity of an existing facility, businesses must determine what portion of the facility’s income can be attributed to the new investment. This has created interpretative difficulties and made the practical application of the exemption more complicated, particularly for businesses expanding or modernising existing production operations.

The proposed amendment would simplify this approach. Income generated by an existing facility could also qualify for the exemption, provided that the existing activities and those covered by the new investment fall under the same Polish Classification of Goods and Services (PKWiU) code.

Importantly, the fundamental eligibility requirement would remain unchanged: the exemption would still apply only to income from activities specified in the support decision. Other activities carried out at the same premises would not automatically qualify.

What this means for businesses: Companies expanding existing production facilities could find it easier to benefit from the PSI exemption. The proposed rules could reduce the complexity of calculating eligible income and potentially increase the amount of income qualifying for tax exemption.

3. Five Additional Years For PSI Exemption

New investors could have up to 20 years to use their available tax exemption. To benefit from the PSI regime, an entrepreneur must first obtain a support decision. This document sets out the investment criteria, the maximum amount of eligible costs, the deadline for completing the investment and the period during which the exemption may be claimed.

Currently, support decisions are issued for periods ranging from 10 to 15 years. The proposed amendment would extend this to 15–20 years providing greater flexibility in planning investments and managing their tax position over the longer term.

However, the extended validity periods would only apply to new support decisions. Decisions issued before the amendment enters into force would retain their existing validity periods.

What this means for businesses: A longer exemption period could make larger and more complex investment projects more attractive, particularly where the full available public aid limit cannot be utilised within the current timeframe.

4. Automation Investments Without New Jobs

Businesses investing exclusively in industrial robots could benefit from the PSI regime without having to commit to creating additional jobs. Obtaining a PSI support decision may currently involve meeting employment-related criteria, including a requirement to create new jobs.

The proposed amendment would introduce an exception for investments involving the robotization and automation of processes through the purchase of industrial robots. Where an entrepreneur declares that all eligible investment costs will relate exclusively to this purpose, the requirement to create new jobs would not apply.

The bill also introduces a definition of an industrial robot consistent with the definition already used for the robotization tax relief.

What this means for businesses: Companies seeking to automate existing production processes could have an additional route to obtaining PSI support, even where their investment does not involve expanding their workforce.

What should investors do now?

The proposed changes could make Poland a more attractive location for manufacturing investment, particularly for businesses planning to expand production capacity, modernise existing facilities or introduce industrial robotics.

Companies considering such projects should review their investment plans and assess how the proposed rules could affect their eligibility for tax incentives and the overall economics of their projects.

Although the bills have not yet been signed, preparing in advance could help businesses take advantage of the new opportunities if the amendments enter into force as planned on 1 January 2027.

For more details and support, get in touch with our Tax Team.

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