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Polish Deal: real properties – changes in CIT


by Maciej Woźnica

20 August 2021

The bill amending the CIT Act, which is one of the key elements of the Polish Deal, includes a number of modifications which greatly affect real estate sector. The key changes include:


  • the tax depreciation of residential property will be non-tax-deductible;
  • tax depreciation rates will be capped (tax depreciation rates will have to be lower than depreciation rates for accounting purposes);
  • refined “thin capitalisation” rules – the higher of: a maximum of 3 million zloty or 30% of tax EBITDA will be tax-deductible costs;
  • intra-group loans granted for financing of capital transactions will be non-tax-deductible.


Furthermore, the bill includes a lot of changes affecting tax implications of all kinds of restructuring measures often taken by real estate market players.


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Anna Harasimowicz

Auditor (Poland)

Associate Partner

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