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Investment agreement


by ​Magdalena Szwarc

8 November 2022

​An investment agreement (the so-called Ruling 590) is a new opportunity offered by the Ministry of Finance which allows investors to mitigate tax risks.

It is an investment agreement concluded between the investor and the Ministry of Finance. It describes the tax implications of an investment project, allows the investor to manage potential tax risks more effectively and opens up the possibility of obtaining a full description of all tax implications of the investment project from revenue authorities.

Ruling 590 is intended to give the investor certainty as to the interpretation of tax laws and to ensure their uniform and consistent interpretation with regard to, among others, the following:

  • assessment that the transfer price determined in transactions between associated enterprises is at arm's length and in compliance with an advance pricing agreement (APA);
  • assessment that the anti-tax avoidance clause does not apply to the tax advantage described in the application; 
  • business clearance;
  • advance tax ruling;
  • binding tariff information;
  • binding VAT rate information.

The investment agreement is concluded for a specific time indicated in the agreement, not longer than five fiscal years, and is binding not only upon the investor but also the revenue authorities.

Who can apply?

  • an investor who plans to commence or has already commenced a new investment project in Poland worth 100 million Polish zloty (from 2025 it will be 50 million Polish zloty); or
  • a group of investors, in particular a consortium, a company, a branch office or a representative office established for the investment project purposes.

What is a new investment project?

The definition is provided in the New Investment Support Act of 10 May 2018, i.e. it is the same as for investment projects for which state aid in the form of an income tax exemption can be applied for as part of their business pursued in the Polish Investment Zone.

Fees and charges

1. Initial: 50 thousand Polish zloty
It should be paid within 30 days of filing the application. It is payable by each investor, also in the case of a joint application. In the event of a refusal to conclude or amend the investment agreement, the fee is refunded to the applicants in full.  

2. Principal: 100 thousand – 500 thousand Polish zloty 
It is specified in the agreement. It should be paid within 30 days of the agreement conclusion. In the case of a joint application, the fee is not payable by each investor.

Procedure – what information must be provided in the application?

  • identification data of the investor (group of investors),
  • an electronic service address, unless the investor has consented to the delivery of letters via the podatki.gov.pl tax portal,
  • a description of the investment planned or underway,
  • the declared investment value and an explanation of how it was determined,
  • the proposed lifetime of the agreement,
  • the proposed subject matter of the agreement.

In order to agree on the scope and content of the investment agreement in the course of the procedure, the Minister of Finance may:

  • ask the investor to clarify any doubts or to supplement the application, including by providing a product sample, or
  • arrange a meeting to clarify details.

Amendments to the agreement, termination, expiry


Contact Person Picture

Magdalena Szwarc

Tax adviser (Poland)

Senior Associate

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