Tax / Special Economic Zones

Special Economic Zones

The Act on Special Economic Zones of 20 October 1994 has been amended several times, mainly because it had to be adjusted to the EU regulations. Changes affected the number of zones, their sizes, and the scope of tax breaks connected with business operations carried out in the zones. Currently, there are 14 special economic zones in Poland, having a total area of 20,000 hectares. They are to remain in existence until 2026.

Special economic zones offer income tax exemption correlated with the amount of capital expenditures within the zone and the costs of two-year employment of new workforce, including social security contributions. Such expenditures are multiplied by the state aid intensity ratio of 15% to 50%, depending on the zone. The resulting amount is income tax exemption that the business does not have to pay.

Special economic zones are not dedicated solely to large entities since the minimum capital expenditure is EUR 100,000. Also, the admissible state aid intensity is higher for small and medium enterprises, by 20 and 10 per cent, respectively.

The advisory services we provide in this respect comprise in particular:

  • presenting detailed principles of business operations conducted in special economic zones and determining the tax exemption, in order to allow an investment viability decision;
  • drafting a letter of intent to indicate compliance of the planned investment with the zone development plan and to stress the expected social and economic benefits from the investment;
  • representing the business entity in tender proceedings or negotiations leading to the issue of a permit to operate in a special economic zone;
  • conducting a legal due diligence and drafting agreements on the acquisition of assets in the special economic zone;
  • determining the business entity’s status under state aid regulations that specify the maximum allowable tax exemption;
  • recognising the capital expenditures in order to determine the due tax breaks;
  • supervising correct calculation of income from activities within the zone and of the applicable tax exemption, including supervision over discounting the allowed tax breaks and the capital expenditures;
  • representing the business entity in proceedings concerning correct determination of the tax exemption.

Please do not hesitate to contact us.


Paweł Stańczyk

Paweł Stańczyk

Tax Planning Practice Leader

+48 22 480 81 00

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