A proposal from the Ministry of Finance would impose an “exit tax” on the transfer of assets from Poland or a change of tax residency.
The exit tax would be imposed on:
The exit tax would not apply with respect assets that would remain with or in a permanent establishment located in Poland.
In the case of natural persons, the exit tax on personal property would apply only if a taxpayer has been a Polish tax resident for at least five years before the change of tax residence.
The basis for the exit tax would be calculated as the surplus of the market value of the transferred asset, determined at the date of the transfer, over its tax value. The tax rate would be:
In the case of natural persons, only the transfer of assets with a market value exceeding PLN 2 million would be subject to taxation (calculated in relation to an individual transaction or for several transactions conducted during a one-year period). For corporate taxpayers, the exit tax would be imposed regardless of the market value of assets.
Taxpayers would be required to file tax returns and report the amount of income subject to exit tax by the seventh day of the month following the month in which the income is realized. At this point, taxpayers would be required to remit the amount of the exit tax. It might be possible to pay the exit tax in installments, over a period of time not to exceed five years.
The proposed effective date would be 1 January 2019.
Read a September 2018 report [PDF 343 KB] prepared by the KPMG member firm in Poland
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