What is a family foundation for?
The family foundation, available in Polish law since 2023, separates business assets from personal ones and enables succession planning without splitting the company among heirs. The founder contributes assets (shares, real estate, cash — minimum PLN 100,000), and the foundation manages them and pays benefits to beneficiaries, usually family members.
Taxation rules
- ongoing activity permitted by statute is CIT-exempt — dividends from held companies, interest, disposal of shares and securities, rental,
- the foundation pays 15% CIT only when paying benefits to beneficiaries or transferring assets upon dissolution,
- beneficiaries from the founder's closest family (spouse, children, grandchildren, parents, siblings) pay no PIT on benefits received; more distant beneficiaries pay 10% or 15%,
- activity beyond the statutory scope is penalised with a 25% CIT rate.
What to watch in 2026
Tax authorities scrutinise foundations used for purposes other than succession — particularly quick sales of contributed assets or aggressive structures involving foreign entities. Recent interpretations have narrowed the exemption for foundations joining partnerships, and clarifications on short-term rental are expected. Before contributing assets, analyse the planned operations against the permitted activity scope.
Formalities and costs
- a notarial founding deed or will + statute,
- registration in the family foundation register kept by the Regional Court in Piotrków Trybunalski,
- founding fund of at least PLN 100,000,
- annual financial statements; audit every 4 years (or annually for larger assets).
Who is it for?
A family foundation works when business assets are to remain undivided across generations and the owner wants to define payout rules in advance. For smaller estates or simple structures, a will, a specific bequest or succession administration often suffice. We help compare these scenarios numerically and coordinate the process with a notary and a lawyer.