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Investment agreement – a new risk management tool


by Magdalena Szwarc ​

16 February 2022


Investment agreement is a new tax law instrument introduced by the Polish Deal. Regulations concerning the investment agreement entered into force on 1 January 2022.


What is an investment agreement?

An investment agreement, the so-called Ruling 590, is an agreement made between an investor and the Minister of Finance which specifies the tax implications of an investment project and allows investors to manage the tax risk more effectively.


An investment agreement is to give the investor certainty as to the interpretation of tax legislation and ensure a uniform and consistent interpretation of tax legislation governing, among others:

  • advance pricing agreement,
  • business clearance,
  • advance tax ruling,
  • binding tariff information,
  • binding VAT rate information.


An investment agreement is concluded for a definite period specified in the agreement, which, however, may not be longer than 5 fiscal years, and is binding on both the investor and tax authorities competent for the investor.


Who can apply?

An application for an investment agreement may be filed by an investor who plans to commence or who has commenced in Poland an investment project worth 100 million zloty (50 million zloty starting from 2025). The application can also be filed by a group of investors, in particular a consortium, a company, a branch office or a representative office established for the investment project purposes.


An investment project is understood as a new investment project in the meaning of the New Investment Support Act, worth at least 100 million zloty.


The initial application fee is 50 thousand zloty and is payable by every investor, even in the case of a joint application. The principal fee is due on conclusion of or amendment to the agreement and its amount is stipulated in the agreement. It can range from 100 to 500 thousand zloty and in the case of a joint application it is not due from every investor.


If you have questions regarding the investment agreement or if you would like to apply for one, you are welcome to contact Rödl & Partner experts.


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Magdalena Szwarc

Tax adviser (Poland)

Senior Associate

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