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Polish "Estonian CIT"

inector

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May 6, 2021
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To benefit from 0% tax until distribution, you need to hire 3 employees, that's fine, but...

the requirement to employ at least three individuals under an employment contract or other civil law contract, subject to PIT and social security contributions

They never mention if employees have to be in Poland...

Can't you employ someone from abroad (from like Spain), pay employer social contributions in Poland, yet still benefit from 0% tax?
 
I would be surprised if that was the intention of the Polish law. Expect pushback from the tax authority if you try to pull that.

On the other hand, you could maybe pull some EU single market argument. If the Polish tax authority declines that, you'd have to go to court and possibly appeal to European courts.
 
If you don't want to hire in Poland don't use Estonian CIT
you'd have to go to court and possibly appeal to European courts.
Well said, thank you Marzio and Sols
 
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