Poland: Tax on financial, lending institutions and insurance companies

Financial institutions tax in Poland

A new law effective 1 February 2016 provides for a tax on banks, lending institutions, and insurance companies. Because of the expanded scope of the legislation, certain entities that conduct lending activities—even to a marginal degree—will be subject to the financial institutions tax.

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KPMG observation

Given the expanded scope of the legislation, there is a risk that entities in a group that grant consumer credit may be regarded as taxpayers subject to the financial institutions tax.

Tax calculation

In general, the tax base is the excess of the sum of the taxpayer’s asset value over a tax-free amount of PLN 200 million (approximately U.S. $50.6 million). The new law provides a method for determining the taxable base with respect of taxpayers operating within a group, subject to the annual rate of tax (as shown in the example below of 0.44%).


To understand this law, consider the following example. 

Companies A, B, and C belong to the same capital group. Companies A and B are lending institutions. Company C is not a lending institution (and thus is not subject to the financial institutions tax). 

The sum of each company's assets is:

  • Company A—PLN 800 million
  • Company B—PLN 150 million
  • Company C—PLN 500 million



The financial institutions tax calculation is made, as follows:

  • Company A—(PLN 800 million + PLN 150 million) minus PLN 200 (i.e., the tax-free amount) x 0.44% = PLN 4.18 million of tax per year.
  • Company B--(PLN 800 million + PLN 150 million) minus PLN 200 (i.e., the tax-free amount) x 0.44% = PLN 4.18 million of tax per year.
  • Company C—No tax


Total financial institutions tax for the group, for the year = PLN 8.36 million


Read a February 2016 report [PDF 318 KB] prepared by the KPMG member firm in Poland: Banking tax – not only for financial institutions and chargeable repeatedly

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