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EXPATRIATE TAX GUIDE
Taxation of income from employment
in the EU & EEA
Poland
2016
CONTENTS*
2	 Austria
4	 Belgium
6	 Bulgaria
8	 Croatia
10	 Cyprus
12	 Czech Republic
14	 Denmark
16	 Estonia
18	 Finland
20	 France
22	 Germany
24	 Greece
26	 Hungary
28	 Iceland
30	 Ireland
32	 Italy
34	 Latvia
36	 Lithuania
38	 Luxembourg
40	 Malta
42	 Netherlands
44	 Norway
46	 Poland
50	 Portugal
52	 Romania
54	 Slovakia
56	 Slovenia
58	 Spain
60	 Sweden
62	 Switzerland
64	 United Kingdom
	
67	 Global Mobility Services in 	
	 GT Poland
Grant Thornton cannot guarantee the accuracy, timeliness or completeness of the data contained herein.
As such, you should not act on the information without first seeking professional tax advice from one of the
contacts at the rear of the publication.
*Poland and Lichtenstein have not conducted a double tax treaty so the latter is excluded from this guidance
1
Introduction
Many companies located in the European Union & European Economic
Area member states are choosing to post their employees to perform work
in the territory of other countries, which places them under obligation to
apply certain laws within those countries.
The issue of labor income taxation is cumbersome
since it requires analysis of the international tax
treaties as well as domestic laws of involved in
each state, especially methods of eliminating
double taxation, social security contributions,
tax return filing, items of salary being subject
to taxation etc.
Let us present pragmatic advice concerning
these issues. We hope you will find this
guide useful while assessing whether
posting employees is advantageous
for your company.
Should you need any further
information or assistant,
please do not hesitate to contact us.
Małgorzata Samborska
Leader of Global Mobility Services
Tax Advisor
2
Austria
Polish Expats in Austria
An Austrian tax charge arises on employment income derived from duties
performed in Austria. There are specific expenses deductible from this
income to the extent that the individual is employed in Austria.
Double Tax Treaty – Austria
Income from employment may be taxed in Austria. Tax exemption
applies if the following conditions are jointly met:
• The stay of the Polish Expat does not exceed in the aggregate
183 days in the fiscal year concerned, and
• The employer of the Polish Expat
is neither a resident of Austria nor
has a permanent establishment
or fixed base in Austria.
Income tax
Progressive, up to 50% (in addition to high social security costs although these
are capped at earnings of €60 000.00 per annum). An employed person is
subject to income tax on wages, allowances and all benefits received from
employment. The tax year in Austria is the calendar year. The annual tax return
must be filed by 30th of April. Married couple are taxed separately, not jointly.
3
Elimination of double taxation:
exemption method - where
a resident of Poland derives income
which may be taxed in Austria,
Poland shall exempt such income
from the Polish tax. Nevertheless,
Poland may in calculating the
amount of Polish tax on the
remaining income of such
resident, take into account
the exempted income or capital.
Austrian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Austria. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Austrian Expat
does not exceed in the aggregate
183 days in the fiscal year
concerned, and
• The employer of the Austrian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
exemption method - where
a resident of Austria derives
income which may be taxed in
Poland, Austria shall exempt such
income from tax. Nevertheless,
Austria may in calculating the
amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
4
Belgium
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in Belgium, on a progressive scale of income tax between 25% and
50% depending on level of income. Local taxes (0% to 10% depending upon
the place of residence) are also payable. There are relatively generous
deductions available including child care, mortgage payments and related
insurance premiums. Tax credits are also available for pension contributions
and life insurance premiums. The tax year in Belgium is the calendar year.
The annual tax return must be filed by 30th of June.
Polish Expats in Belgium
Under certain conditions, a foreign executive assigned temporarily to
Belgium within an international group of companies may qualify for
a special taxation regime. The executive will be treated for Belgian tax
purposes as a nonresident, liable to Belgian personal income tax on
his/her Belgian-source income only. The expatriate will not be taxed on
supplementary recurring and non-recurring expenses (up to an amount
of €11,250 or €29,750 per year) which are incurred as a result of his/her
recruitment or transfer to Belgium, whether paid as lump sum allowances
or as specific reimbursements of outgoings (i.e. housing allowances, cost
of living allowances, tax equalization etc.). In addition to these tax free
allowances which can be paid by the employer,
the proportion of overall
remuneration relating
to working days
spent abroad on
business is excluded
from taxable income
(the so-called ‘travel exclusion’).
5
Double Tax Treaty – Belgium
Income from employment may
be taxed in Belgium. Tax exemption
applies, if the following conditions
are jointly met:
• The stay of the Polish Expat does
not exceed in the aggregate 183
days in any twelve-month period
commencing or ending in the tax
year concerned, and
• The employer of the Polish Expat
is neither a resident of Belgium nor
has a permanent establishment or
fixed base in Belgium.
Elimination of double taxation: credit
method - where a resident of Poland
derives income which may be taxed
in Belgium, Poland shall allow as
a deduction from the Polish tax of
that person, an amount equal to the
Belgian tax paid under Belgian law,
as computed by reference to the
same income to which the Polish
tax is computed.
Belgian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies, if the following conditions
are jointly met:
• The stay of the Belgian Expat does
not exceed in the aggregate 183
days in any twelve-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Belgian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
exemption method - where
a resident of Belgium derives
income which may be taxed in
Poland, Belgium shall exempt such
income from tax. Belgium may
in calculating the amount of tax
on the remaining income of such
resident apply the rate of tax which
would have been applicable if the
exempted income had not been
so exempted.
6
Bulgaria
Polish Expats in Bulgaria
Every citizen of Poland who works in Bulgaria, in whom there
is an obligation in terms of the PIT or insurance, has a duty to
register at the relevant Bulgarian tax authorities, in order to obtain
an identification number. Income of any kind of premiums,
bonuses, benefits in kind, etc., acquired from work in the territory
of Bulgaria, beyond the basic salary,
is also subject to taxation.
If the employment contract is concluded
with the Bulgarian employer,
he is obliged to calculate and pay
monthly income tax payments.
In the case of a contract with the employer
not established in Bulgaria, the employee
should independently calculate and pay
monthly advance income tax.
Income tax
Regardless of the status of tax residence, income from employment is subject
to income tax of 10%. Deadline for submission of tax returns and replenishment
of any underpaid taxes is 30 April the following year. The tax year in Belgium is
the calendar year. Interestingly, the Bulgarian tax authorities provide all sorts
of “discount” for taxpayers that make a statement electronically, e.g. if the
Bulgarian taxpayers filed tax returns for year 2013 to 5 February 2014, they
could count on lowering any shortfall by 5%.
7
Double Tax Treaty – Bulgaria
Income from employment may
be taxed in Bulgaria. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat does
not exceed in the aggregate 183
days in any twelve-month period,
and
• The employer of the Polish Expat
is neither a resident of Bulgaria nor
has a permanent establishment or
fixed base in Bulgaria.
Elimination of double taxation:
exemption method - where
a resident of Poland derives income
which may be taxed in Bulgaria,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Bulgarian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Bulgarian Expat
does not exceed in the aggregate
183 days in any twelve-month
period, and
• The employer of the Bulgarian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
exemption method – where
a resident of Bulgaria derives
income which may be taxed in
Poland, Bulgaria shall exempt such
income from tax. Bulgaria may
in calculating the amount of tax
on the remaining income of such
resident apply the rate of tax which
would have been applicable if the
exempted income had not been so
exempted.
8
Croatia
Polish Expats in Croatia
Pole acquiring his income from work in the territory of Croatia, beyond
the basic salary, is also required for taxation of any kind of premiums,
bonuses, benefits in kind, etc. There are some employee benefits that
are not taxed to the limit specified by law. If the employment contract
is concluded with the Croatian employer,
he is obliged to calculate and pay monthly
income tax payments.
Double Tax Treaty – Croatia
Income from employment
may be taxed in Croatia. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat does not exceed
in the aggregate 183 days in the calendar year, and
• The employer of the Polish Expat is neither a resident of
Croatia nor has a permanent establishment or fixed base in Croatia.
Income tax
Croatian tax system has a progressive scale for income tax from individuals.
The scale consists of three thresholds of 12%, 25% and 40% and depends
on the amount of income.
In addition to the basic income tax, Croatian tax system also provides
tax equalization, the amount of which depends on the municipality,
which is inhabited by the taxpayer. Deadline for submission of tax returns
and payment of any back taxes is end of February of the following year.
9
Elimination of double taxation:
exemption method - where
a resident of Poland derives income
which may be taxed in Croatia,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Croatian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Croatian Expat
does not exceed in the aggregate
183 days in the calendar year, and
• The employer of the Croatian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method - where a resident
of Croatia derives income which
may be taxed in Poland, Croatia
shall allow as a deduction from
the Croatian tax of that person,
an amount equal to the Polish tax
paid under Polish law, as computed
by reference to the same income
to which the Croatian tax is
computed.
10
Cyprus
Polish Expats in Cyprus
Expatriates are entitled to an income tax exemption for the lower
of 20% of emoluments and €8,550 per annum for the first three
years of employment in Cyprus. Expatriates earning over €100,000 per
annum are entitled to a 50% exemption for a period of up to five years.
Double Tax Treaty – Cyprus
Income from employment may be taxed in Cyprus. Tax exemption applies
if the following conditions are jointly met:
• The stay of the Polish Expat does not exceed in the aggregate 183 days
in any twelve-month period, and
• The employer of the Polish Expat is neither a resident of Cyprus
nor has a permanent establishment or fixed base in Cyprus.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for
duties performed in Cyprus, on a progressive scale from 0% to 35%. Various
personal expenses are allowed as a deduction for tax purposes including life
insurance premiums, social insurance contributions, approved provident fund
contributions, approved medical scheme contributions. The tax year
in Cyprus is the calendar year. The annual tax return must be filed by 30th
of April or 31 July (if submitted through TAXISnet) in the following tax year.
11
Elimination of double taxation:
exemption method - where
a resident of Poland derives
income which may be taxed in
Cyprus, Poland shall exempt such
income from tax. Nevertheless,
in calculating the amount of tax
on the remaining income of such
resident, Poland may take into
account the exempted income.
Cypriot Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Cypriot Expat
does not exceed in the aggregate
183 days in any 12-month period,
and
• The employer of the Cypriot
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method - where a resident
of Cyprus derives income which
may be taxed in Poland, Cyprus
shall allow as a deduction from
the Cypriot tax of that person,
an amount equal to the Polish tax
paid under Polish law, as computed
by reference to the same income to
which the Cypriot tax is computed.
12
The Czech Republic
Polish Expats in the Czech Republic
A Czech tax charge arises on employment income derived from duties
performed in the Czech Republic based on the gross salary plus social and
health insurance paid by the employer. Assessable employment income
includes all wages, salaries, overtime pay, bonuses, gratuities, perquisites,
benefits etc. including the reimbursement of travel expenses over a certain
level. There are no specific concessions for expatriates.
Double Tax Treaty – the Czech Republic
Income from employment may be taxed
in the Czech Republic.Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period, and
• The employer of the Polish Expat
is neither a resident of the Czech Republic nor
has a permanent establishment or fixed base in the Czech Republic.
Income tax rate
Resident individuals are subject to flat personal income tax rate of 15%. Solidary
tax increase of 7% for income exceeding the amount of the average wage
announced by the Czech social insurance authorities multiplied by 48
(i.e. exceeding the amount of approx. €45,446 in 2014). The tax year
in the Czech Republic is the calendar year. The annual tax return must
be filed by 1st of April. Married couple are taxed separately, not jointly.
13
Elimination of double taxation:
exemption method – where
a resident of Poland derives income
which may be taxed in the Czech
Republic, Poland shall exempt
such income from tax. Poland may
in calculating the amount of tax
on the remaining income of such
resident apply the rate of tax which
would have been applicable if the
exempted income had not been so
exempted.
Czech Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Czech Expat does
not exceed in the aggregate 183
days in any 12 – month period
concerned, and
• The employer of the Czech Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation:
credit method - the Czech Republic
when imposing taxes on its
residents may include in the tax
base income which may also be
taxed in Poland, but shall allow as
a deduction from the amount of
tax computed on such a base an
amount equal to the tax paid in
Poland. Such deduction shall not,
however, exceed that part of the
Czech Republic tax, as computed
before the deduction is given,
which is appropriate to the income
which may be taxed in Poland.
14
Denmark
Polish Expats in Denmark
Foreign key employees working temporarily in Denmark, who have not
been subject to Danish taxation (on certain income) in the previous
10 years, may choose to be taxed at a flat rate of 26% of their gross
salary plus a labour market contribution of 8%, resulting in a total tax
of approximately 32% of their gross salary (for up to 60 months).
Certain requirements must be met in order to qualify for the expat regime.
Double Tax Treaty – Denmark
Income from employment may be taxed in Denmark.
Tax exemption applies if the following
conditions are jointly met:
• The stay of the Polish Expat does not
exceed in the aggregate 183 days in any
12-month period commencing or ending
in the fiscal year concerned, and
• The employer of the Polish Expat is neither
a resident of Denmark nor has a permanent
establishment or fixed base in Denmark.
Income tax
Progressive up to 51,95%. The Danish tax rates are among the highest in
Europe. The Danish tax system, however, provides a number of reliefs and
exemptions that reduce the tax base. The tax year coincides with the calendar
year, and the deadline for filing a tax return is 1st of July of the following year.
In Denmark, there are two tax-free amounts - one limit shall apply to persons
under 18 years of age, while the second: persons over 18 years of age.
15
Elimination of double taxation:
exemption method - where
a resident of Poland derives income
which may be taxed in Denmark,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Danish Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Danish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Danish
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method - where a resident
of Denmark derives income which
may be taxed in Poland, Denmark
shall allow as a deduction from
the Danish tax of that person, an
amount equal to the Polish tax paid
under Polish law, as computed by
reference to the same income to
which the Danish tax is computed.
16
Estonia
Polish Expats in Estonia
No special favorable tax regime for expatriates. Non-residents pay tax only
on their income received from Estonian sources. Rules for the calculation
and payment of monthly advances and the right to benefit from tax relief
for non-residents is just as for tax residents.
Double Tax Treaty – Estonia
Income from employment may be taxed
in Estonia. Tax exemption applies if
the following conditions are jointly
met:
• The stay of the Polish Expat does not
exceed in the aggregate 183 days in any
12-month period commencing or ending
in the fiscal year concerned, and
• The employer of the Polish Expat is neither
a resident of Estonia nor has a permanent establishment
or fixed base in Estonia.
Income tax
The tax rate for 2015 is 20% of the taxable income. The tax year coincides
with the calendar year. The deadline for submitting a tax return expires
on 31st March of the following year. Estonian tax system provides
many tax reliefs and exemptions that reduce the tax base, these include,
among others, a joint settlement with the spouse. In addition to tax relief,
tax residents of Estonia can count on many exemptions for benefits
in kind - many of them are not subject to PIT.
17
Elimination of double taxation:
exemption method – where
a resident of Poland derives income
which may be taxed in the Estonia,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Estonian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may
be taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Estonian Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Estonian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method - where a resident
of Estonia derives income which
may be taxed in Poland, Estonia
shall allow as a deduction from
the Estonian tax of that person, an
amount equal to the Polish tax paid
under Polish law, as computed by
reference to the same income to
which the Danish tax is computed.
18
Finland
Polish Expats in Finland
A Finnish tax charge arises on employment income derived from duties
performed in Finland. Assessable employment income includes all wages,
salaries, overtime pay, bonuses, gratuities, perquisites, benefits etc. There
are no specific expatriate concessions in Finland.
Double Tax Treaty – Finland
Income from employment may be taxed in Finland.
Tax exemption applies if the following conditions
are jointly met:
• The stay of the Polish Expat does not exceed in
the aggregate 183 days in any 12-month period
commencing or ending in the calendar year
concerned, and
• The employer of the Polish Expat is neither
a resident of Finland nor has a permanent
establishment or fixed base in Finland.
Income tax
Finnish tax system has a progressive scale for income tax from individuals.
The scale consists of five tax thresholds: 6.5%, 17.5%, 21.5%, 29.75% and
31.75% and depends on the amount of income. In addition to basic income,
Finnish tax system also provides for a municipal tax, the amount of which
depends on the municipality, which is inhabited by the taxpayer. Interestingly,
people who are members of churches of the Evangelical-Lutheran or Orthodox,
are obliged to pay a tax of 1-2% of income. The tax year coincides with the
calendar year. Married couple are taxed separately, not jointly.
19
Elimination of double taxation:
exemption method – where a
resident of Poland derives income
which may be taxed in Finland,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Finnish Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Finland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Finnish Expat does
not exceed in the aggregate 183
days in the calendar year concerned,
and
• The employer of the Finnish
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Finland derives income which
may be taxed in Poland, Finland
shall allow as a deduction from
the Finnish tax of that person, an
amount equal to the Polish tax paid
under Polish law, as computed by
reference to the same income to
which the Finnish tax is computed.
20
France
Polish Expats in France
A French tax liability arises on income derived from duties performed
in France. For new residents seconded to France (impatriates),
allowances related to secondment and remuneration related to
workdays spent out of France are tax exempt, under certain conditions.
Double Tax Treaty – France
Income from employment is taxed in France.
Tax exemption applies if the following
conditions are jointly met:
• The stay of the Polish Expat does not exceed
in the aggregate 183 days in the tax year, and
• The employer of the Polish Expat is neither
a resident of France nor has a permanent
establishment or fixed base in France.
Income tax
French tax system has a progressive scale for income tax from individuals.
The scale consists of four tax threshold: 14%, 30%, 41 and 45% and depends
on the amount of income. An employed person is subject to income tax
on wages, allowances and benefits in kind received from employment (for
example company car used for private purposes). The taxable base depends
on members of family – for example; if a married couple have one child their
taxable income is divided into 3. The tax year is the calendar year. Married
persons must file annual tax return jointly, not separately. Filing a tax
return is mandatory before end of May (end of June if filing online).
21
Elimination of double taxation:
exemption method – where a
resident of Poland derives income
which may be taxed in France,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
French Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment is taxed
in Poland. Tax exemption applies if
the following conditions are jointly
met:
• The stay of the French Expat does
not exceed in the aggregate 183
days in the fiscal year, and
• The employer of the French
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
exemption method - where a
resident of France derives income
which may be taxed in Poland
under rules of Double Tax Treaty,
France shall exempt such income
from tax. France may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
22
Germany
Polish Expats in Germany
No special expatriate regime. In general, individual taxpayers are
allowed to claim all expenses directly incurred with their income
from employment. There is a tax free lump sum for these expenses for
employees at an amount of €1,000. Thereafter, various other deductions
and allowances apply on taxable income.
Double Tax Treaty – Germany
Income from employment may be taxed in Germany.
Tax exemption applies if the following conditions
are jointly met:
• The stay of the Polish Expat does not exceed in
the aggregate 183 days in any 12-month period
commencing or ending in the tax year concerned,
• The employer of the Polish Expat is neither
a resident of Germany nor has a permanent
establishment or fixed base in Germany.
The abovementioned exemption does not apply if:
• under employment contract the employee performs services in favour
of entity other than the employer, who controls directly or indirectly the
manner of exercise of such a performance and
• the employer does not bear the responsibility or risk of effect of the
employee’s performance
Income tax
German tax system has a progressive scale for income tax from individuals.
Rates are progressive starting at 14% up to 45% and depend on the amount
of income. Tax base is different for single and married. Married couples may
choose to be assessed either jointly or separately. The tax year is the calendar
year. The deadline for submitting a tax return expires on 31st of May of the
following year.
23
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Germany,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
German Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the German Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the German
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
The abovementioned exemption
does not apply if:
• under employment contract
the employee performs services
in favour of entity other than the
employer, who controls directly or
indirectly the manner of exercise of
such a performance and
the employer does not bear the
responsibility or risk of effect of the
employee’s performance
Elimination of double taxation:
exemption method - where a
resident of Germany derives income
which may be taxed in Poland,
Germany shall exempt such income
from tax. German tax authorities
may in calculating the amount of
tax on the remaining income of
such resident apply the rate of tax
which would have been applicable if
the exempted income had not been
so exempted.
24
Greece
Polish Expats in Greece
A Greek tax charge arises on employment income derived from duties
performed in Greece. Taxable employment income includes all wages,
salaries, overtime pay, bonuses, gratuities, perquisites, benefits etc. There
is also a requirement on the expatriate’s employer to deduct Greek payroll
withholding tax from the taxable employment income. There are no
specific expatriate concessions in Greece.
Double Tax Treaty – Greece
Income from employment may be taxed
in Greece. Tax exemption applies if
the following conditions are jointly met:
• The stay of the Polish Expat does not
exceed in the aggregate 183 days in
calendar year concerned, and
• The employer of the Polish Expat is neither
a resident of Greece nor has a permanent
establishment or fixed base in Greece.
Income tax
Greek tax system has a progressive scale for income tax from individuals.
The scale consists of three tax threshold: 22%, 32% and 42% and depends on
the amount of income. An individual whose income is only from a wage is not
obligated to file an annual return. Greek tax system provides many tax reliefs
and exemptions that reduce the tax base. Married couple must file annual
tax return jointly, but they are taxed separately.
25
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Greece,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Greek Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Greek Expat does
not exceed in the aggregate 183
days in calendar year concerned,
and
• The employer of the Greek Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation: credit
method – where a resident of Greece
derives income which may be taxed
in Poland, Greece shall allow as a
deduction from the Greek tax of
that person, an amount equal to the
Polish tax paid under Polish law, as
computed by reference to the same
income to which the Greek tax is
computed.
26
Hungary
Polish Expats in Hungary
Expatriates are subject to Hungarian tax on the portion of income
attributable to work in Hungary.
Double Tax Treaty – Hungary
Income from employment may be taxed in Hungary. Tax exemption
applies if the following conditions are jointly met:
• The stay of the Polish Expat does not exceed in the aggregate
183 days in the fiscal year concerned, and
• The employer of the Polish Expat is neither
a resident of Hungary nor
has a permanent
establishment or fixed
base in Hungary.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed at a rate of 16%. Employers’ social security contributions are payable
at 27%. Employees pay 8.5% health and unemployment contribution and 10%
pension contribution without limitation. The tax year is the calendar year.
The deadline for submitting a tax return expires on 20th May following year.
Married couples are taxed separately.
27
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Hungary,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Hungarian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Hungarian
Expat does not exceed in the
aggregate 183 days in the fiscal year
concerned, and
• The employer of the Hungarian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
exemption method - where a
resident of Hungary derives
income which may be taxed in
Poland, Hungary shall exempt such
income from tax. Hungary may
in calculating the amount of tax
on the remaining income of such
resident apply the rate of tax which
would have been applicable if the
exempted income had not been so
exempted.
28
Iceland
Polish Expats in Iceland
The person who holds a domicile or habitual residence (center of vital
interests, leisure activities etc.) in the territory of Iceland is considered
as a tax resident in Iceland. As a rule, the expenses concerning an
employment incurred by employee are not deductible. However,
some kinds of costs related to an accommodation or meals of posted
employee may be deductible.
Double Tax Treaty – Iceland
Income from employment may be taxed in Iceland. Tax exemption
applies if the following conditions are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month
period commencing or ending
in the fiscal year concerned, and
• The employer of the Polish Expat
is neither a resident of Iceland nor
has a permanent establishment
or fixed base in Iceland.
Income tax
Icelandic tax system has three tax rates: 37,13%, 38,35% and 46,25%.
An employed person is subject to income tax on wages, allowances and
benefits in kind received from employment. The employer is obliged to withhold
the part of employee’s salary for the social and health security contributions.
The deadline for submitting a tax return expires on the end of March
the following year. Married couple are taxed separately.
29
Elimination of double taxation:
exemption method – where a
resident of Poland derives income
which may be taxed in Iceland,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Icelandic Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Icelandic Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Icelandic
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Iceland derives income which
may be taxed in Poland, Iceland
shall allow as a deduction from
the Icelandic tax of that person,
an amount equal to the Polish tax
paid under Polish law, as computed
by reference to the same income
to which the Icelandic tax is
computed.
30
Ireland
Polish Expats in Ireland
Tax free subsistence payments are possible for secondment in certain
circumstances and there are incentives for high paid expatriates.
Double Tax Treaty – Ireland
Income from employment may be taxed in Ireland.
Tax exemption applies if the following conditions
are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in the fiscal year, and
• The employer of the Polish Expat
is neither a resident of Ireland nor
has a permanent establishment
or fixed base in Ireland.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in Ireland, on a two tier system of income tax rates starting at 20%
up to €33,800 and 40% on income exceeding €33,800. The Irish tax system
is similar to British. Just like in the UK, the Irish employers are obliged
to withhold so-called PAYE (Pay As You Earn) of the employees’ wages.
An employed person is subject to income tax on wages, allowances
and benefits in kind received from employment. The tax year is the calendar
year. The deadline for submitting a tax return expires on 31st of October.
Married couple are taxed jointly or separately.
31
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Ireland,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Irish Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Irish Expat does
not exceed in the aggregate 183
days in the fiscal year, and
• The employer of the Irish Expat is
neither a resident of Poland nor has
a permanent establishment or fixed
base in Poland.
Elimination of double taxation:
credit method – where a resident of
Ireland derives income which may
be taxed in Poland, Ireland shall
allow as a deduction from the Irish
tax of that person, an amount equal
to the Polish tax paid under Polish
law, as computed by reference to
the same income to which the Irish
tax is computed.
32
Italy
Polish Expats in Italy
There are a few specific concessions for expatriates.
Income includes all amounts paid or
accrued in a calendar year and paid by
12 January of the following calendar
year as salary, wages, commissions,
director’s fees, bonuses and taxable benefits.
Employment income derived by Italian tax
residents who work abroad on a continuous
basis for more than 183 days is taxed on
a conventional reduced taxable basis.
Income tax
Italian tax system has a progressive scale for income tax from individuals.
The scale consists of five tax thresholds: 23%, 27%, 38%, 41% and 43% and
depends on the amount of income. An additional surcharge of 3% applies to
income exceeding €300,000. There is also a regional tax of up to 3.33% and
a municipal tax of 0.1%-0.9% depending on a region. An employed person is
subject to income tax on wages, allowances and benefits in kind received from
employment. The tax year is the calendar year. The deadline for submitting
a tax return expires on the end of September. Married persons are taxed
separately.
33
Double Tax Treaty – Italy
Income from employment may
be taxed in Italy. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat does
not exceed in the aggregate 183
days in the calendar year concerned,
and
• The employer of the Polish Expat
is neither a resident of Italy nor has
a permanent establishment or fixed
base in Italy.
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Italy, Poland
shall exempt such income from
tax. Poland may in calculating the
amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Italian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Italian Expat does
not exceed in the aggregate 183
days in the calendar year concerned,
and
• The employer of the Italian Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation: credit
method – where a resident of Italy
derives income which may be taxed
in Poland, Italy shall allow as a
deduction from the Italian tax of
that person, an amount equal to the
Polish tax paid under Polish law, as
computed by reference to the same
income to which the Italian tax is
computed.
34
Latvia
Polish Expats in Latvia
There is no special expatriate tax regime and for tax purposes they are
treated as residents.
Double Tax Treaty – Latvia
Income from employment may be taxed in Latvia.
Tax exemption applies if the following
conditions are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal year concerned, and
• The employer of the Polish Expat is neither a resident of Latvia nor
has a permanent establishment or fixed base in Latvia.
Income tax
Latvian tax system has a flat rate of 23% for individuals’ income. An employed
person is subject to income tax on wages, allowances and benefits in kind
received from employment (for example: company’s car usage). The Latvian
employers are obliged to withhold tax advances and social security contribution
on personal salary and provide the proper authorities with these amounts.
The tax year is the calendar year. The deadline for submitting a tax return
expires on 1st of June.
35
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Latvia,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Latvian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Latvian Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Latvian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation: credit
method – where a resident of Latvia
derives income which may be taxed
in Poland, Latvia shall allow as a
deduction from the Latvian tax of
that person, an amount equal to the
Polish tax paid under Polish law, as
computed by reference to the same
income to which the Latvian tax is
computed.
36
Lithuania
Polish Expats in Lithuania
Resident individuals are taxed on their worldwide income. Non-residents
are subject to Lithuanian tax on income originating in Lithuania.
Generally, income or compensations received by an expatriate for both
business and private purposes such as cost of living, relocation expenses,
settling expenses, schooling allowance are added to the income and taxed
accordingly.
Double Tax Treaty – Lithuania
Income from employment may be taxed
in Lithuania. Tax exemption applies
if the following conditions are jointly
met:
• The stay of the Polish Expat does not exceed
in the aggregate 183 days in any 12-month period
commencing or ending in the fiscal year concerned, and
• The employer of the Polish Expat is neither a resident
of Lithuania nor has a permanent establishment or fixed base in Lithuania.
Income tax
The Lithuanian tax system has a flat rate of 15%. An employed person
is subject to income tax on wages, allowances and benefits in kind received
from employment. The tax year is the calendar year. The deadline for submitting
an annual tax return expires on 1st May of the following year.
37
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Lithuania,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Lithuanian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Lithuanian Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Lithuanian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Lithuania derives income which
may be taxed in Poland, Lithuania
shall allow as a deduction from
the Lithuanian tax of that person,
an amount equal to the Polish tax
paid under Polish law, as computed
by reference to the same income
to which the Lithuanian tax is
computed.
38
Luxembourg
Polish Expats in Luxembourg
Since 1st January 2011 there has been
a special tax regime for expatriates.
The regime only applies to highly skilled
expatriates and provides a tax relief
in respect of certain relocation expenses
incurred. A written application must be
submitted to the Luxembourg tax authorities
and if the relevant conditions are met
the Luxembourg tax authorities
will confirm that the regime applies.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in Luxembourg, on a progressive scale from 0% to 40%. In addition,
a solidarity tax is payable at 7% (or 9% for taxable income exceeding €150,000)
of the calculated income tax due. There are general deductions allowable
in determining an individual’s taxable income for both business and private
purposes such as life assurance and health insurance premiums, childcare
costs, loan interest and personal pension contributions. The tax year is the
calendar year. The deadline for submitting a tax return expires on 31st of
March.
39
Double Tax Treaty – Luxembourg
Income from employment may
be taxed in Luxembourg. Tax
exemption applies if the following
conditions are jointly met:
• The stay of the Polish Expat does
not exceed in the aggregate 183
days in the calendar year concerned,
and
• The employer of the Polish Expat
is neither a resident of Luxembourg
nor has a permanent establishment
or fixed base in Luxembourg.
Elimination of double taxation:
exemption method - where
a resident of Poland derives
income which may be taxed in
Luxembourg, Poland shall exempt
such income from tax. Poland may
in calculating the amount of tax
on the remaining income of such
resident apply the rate of tax which
would have been applicable if the
exempted income had not been so
exempted.
Luxembourgian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Luxembourgian
Expat does not exceed in the
aggregate 183 days in the calendar
year concerned, and
• The employer of the
Luxembourgian Expat is neither
a resident of Poland nor has a
permanent establishment or fixed
base in Poland.
Elimination of double taxation:
exemption method - where a
resident of Luxembourg derives
income which may be taxed in
Poland, Luxembourg shall exempt
such income from tax. Luxembourg
may in calculating the amount of
tax on the remaining income of
such resident apply the rate of tax
which would have been applicable if
the exempted income had not been
so exempted.
40
Malta
Polish Expats in Malta
Expatriates are only taxed in Malta on their
Maltese-sourced and remitted income. Foreign
gains remitted to Malta are not taxable in Malta.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in Malta, on a progressive scale from 15% to 35%. Highly qualified
non-Malta domiciled individuals employed in an eligible office within a company
that is licensed and/ or recognized by the Malta Financial Services Authority,
the Lotteries and Gaming Authority or the Transport Authority, having an annual
income in excess of €75,000, may benefit from a flat personal tax rate of
15%. The same principle applies for individuals engaged in the development
of innovative and creative digital products occupying specific designations
and having minimum income of €45,000. Furthermore, this 15% flat personal
tax status is also available for high net worth individuals (subject to certain
conditions being satisfied) applicable on foreign income remitted to Malta
subject to a minimum annual amount of €20,000 (and €2,500 for every
dependant) for EU, EEA and Swiss nationals and €15,000 (and €5,000 for
every dependant) for non-EU/EEA/Swiss nationals, after double taxation relief.
A similar programme applicable to retirement planning is in place subject
to an annual minimum tax charge of €7,500 on pension income.
41
Double Tax Treaty – Malta
Income from employment may
be taxed in Malta. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Polish Expat
is neither a resident of Malta nor
has a permanent establishment or
fixed base in Malta.
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Malta,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Maltese Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Maltese Expat
does not exceed in the aggregate
183 days in the calendar year
concerned, and
• The employer of the Maltese
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation: credit
method – where a resident of Malta
derives income which may be taxed
in Poland, Malta shall allow as a
deduction from the Maltese tax of
that person.
42
The Netherlands
Polish Expats in the Netherlands
The Netherlands has a special tax regime for expatriates, ‘the 30% ruling’.
If the employee has specific expertise, has been required from abroad and
works for an employer who is a Dutch wage tax-withholding agent,
then 30% of gross income may be paid out without
being subject to income tax. This results in
an effective rate of income tax (and social
security contributions) for expatriates of
36.4%. Expatriates may also be entitled
to special deductions for relocation
related expenses.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in the Netherlands, on a progressive scale up to 52%, inclusive of
social security contributions. Generally certain benefits can be provided on
a tax efficient basis including child care arrangements, company car, cost of
living allowance, schooling, housing, medical expenses, relocation expenses
and pension arrangements. The tax year is the calendar year. The deadline
for submitting a tax return expires on 1st April of the following year. Married
persons are taxed separately.
43
Double Tax Treaty – the Netherlands
Income from employment may
be taxed in the Netherlands. Tax
exemption applies if the following
conditions are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Polish
Expat is neither a resident of the
Netherlands nor has a permanent
establishment or fixed base in the
Netherlands.
Elimination of double taxation: credit
method - where a resident of Poland
derives income which may be taxed
in the Netherlands, Poland shall
allow as a deduction from the Polish
tax of that person, an amount equal
to the Dutch tax paid under Dutch
law, as computed by reference to the
same income to which the Polish
tax is computed.
Dutch Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Dutch Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Dutch Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation:
exemption method - where a
resident of the Netherlands derives
income which may be taxed in
Poland, the Netherlands shall
exempt such items of income by
allowing a reduction of its tax.
This reduction shall be computed
in conformity with the provisions
of Dutch law for the avoidance of
double taxation.
44
Norway
Polish Expats in Norway
Double Tax Treaty – Norway
Income from employment may be taxed in Norway. Tax exemption
applies if the following conditions are jointly met:
• The stay of the Polish Expat does not exceed
in the aggregate 183 days in any 12-month period
commencing or ending in the tax year concerned,
and
• The employer of the Polish Expat is neither
a resident of Norway nor has a permanent
establishment or fixed base in Norway.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in Norway, on a progressive scale from 0% to 12%. The taxpayers
are also obligated to pay combined national and municipal income tax rated
at 24,5%-28% depending on a region. The rate of social security contribution
amounts to 7,8%. The Norwegian employers are obliged to withhold tax
advances and social security contribution on personal salary and provide the
proper authorities with these amounts. The tax year is the calendar year. The
deadline for submitting the annual tax return expires on 30th of April in the year
following the income year. Married couple may choose to be assessed either
jointly or separately.
45
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Norway,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Norwegian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Norwegian Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Norwegian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method - where a resident
of Norway derives income which
may be taxed in Poland, Norway
shall allow as a deduction from the
Norwegian tax of that person, an
amount equal to the Polish tax paid
under Polish law, as computed by
reference to the same income to
which the Polish tax is computed.
This reduction shall be computed
in conformity with the provisions
of Norway law for the avoidance of
double taxation.
46
Poland
Individuals
Taxation in Poland depends upon the residence status of the individual.
• Non-residents pay tax only on Polish sourced income.
• Residents pay tax on their worldwide income (from both Polish and foreign
sources).
The tax year for individuals is equal to the calendar year ending on
31 December.
Residence
An individual person is recognized as having a place of residence on the
territory of Poland, if:
1. holds a personal or business interest center (center of vital interest)
on the territory of Poland or
2. stays on the territory of Poland more than 183 days in a tax year,
unless a relevant Double Taxation Treaty states otherwise.
It means that generally the individual who
stays in Poland for more than 183 days
is treated as a Polish tax resident subject
to taxation on his/her worldwide income.
However, if the individual is also a resident
in another country, he/she shall be deemed
to be a resident only of the state with his/her
personal and economic relations are closer
(center of vital interests).
47
Tax scale 2015
The table shows the tax brackets applicable in 2015
Taxation Base (PLN) In 2015 a tax amounts to:
Over Up to
85,528 18% minus the tax reducing amount
PLN 556.02
85,528 PLN 14,839.02 + 32% on the surplus
over PLN 85,528.00
Taxation of salaries and wages
Taxable employment income
includes all wages, salaries, overtime
pay, bonuses, gratuities, perquisites,
benefits in kind etc. Remuneration
for work carried out in Poland is
treated as Polish-sourced income
(no matter where the employer
is located). In the case when an
employee derives remuneration
from a Polish employer being
a Polish resident or from a
permanent establishment which a
foreign enterprise has in Poland,
the said employer or permanent
establishment is obliged to:
• calculate and declare advance
payments at 18% or 32% tax rates;
• calculate the annual tax
settlement for the employee who
opts for it (on an official tax form);
• prepare information (on an
official tax form) about the income
derived or tax loss sustained if the
employee submits the tax return on
his/her own.
If the employee receives the
remuneration directly from abroad
(from the employer who has the
place of residence or place of living
abroad) he/she is obliged to pay
personal income tax in the form
of advance payments by himself/
herself. The amount of the advance
payment is to be calculated with
the 18% tax rate (the taxpayer
can also use a 32% tax rate when
appropriate).
Personal income tax payers may
take advantage of a special tax relief
for the Polish tax residents who
earn certain kinds of income on the
territory of foreign countries, where
the double taxation is avoided by
using the proportional tax credit
method (so-called tax abolition
relief).
48
Poland
Tax deductible costs
A deduction of 111.25 PLN per month is available in respect of expenses
associated with earning employment income. The deduction amounts
to 139.06 PLN per month in case when a taxpayer’s place of permanent
or temporary residence is outside the limits of a district where his or her
employment’s establishment exists and the taxpayer does not receive a
family separation allowance. Those with more than one employment are
entitled to an increased deduction up to 1.5 times of the maximum.
An annual tax credit of 556.02 PLN is available to all individuals who have
a taxable presence in Poland.
Healthcare contributions
Healthcare contributions (9% of gross income decreased by social security)
are deductible from tax up to 7.75% of the assessment base.
Social security contributions
Social security contributions (also paid abroad) are deductible from the
tax base.
Child deduction
There is also the possibility of benefit from child deductions - available
for parents bringing up children (if certain conditions are met) - up to
1,112.04 PLN annually per child (in 2015); 2,224.08 PLN for two
children; 4,224.12 PLN for 3 children; 6,924.12 PLN for 4 children and
additionally 2,700 for each next child.
Monthly advance payments
The successive advance payments should be paid on the 20th day of the
month following the month when the income was obtained (e.g. for
income obtained in September on 20th October). The tax amount for
December should be paid when submitting the annual Polish tax return.
49
Tax Returns
The tax year in Poland begins
on 1st January and ends on 31st
December. An individual should
submit the annual tax return no
later than on 30th April of a year
following a given tax year (or before
leaving Poland if it appears earlier).
Married couple may file a joint
return if they have unlimited tax
liability and if they are married the
entire tax year and have a marital
co-ownership during the entire tax
year (this scheme is also applicable
for non-residents from an EEA
member country, obtaining at
least 75% of their global income
in Poland). A joint tax return
also applies to single parents with
dependent children. The joint tax
return leads to essential tax savings
if the other person (spouse or
dependent child) does not receive
any tax income or the income is
low.
The Personal Income Tax Act
does not apply to revenue which
is subject to the provisions on tax
on inheritance and donations,
actions that cannot be the subject
of a legally binding agreement, or
revenue subject to tonnage tax.
50
Portugal
Polish Expats in Portugal
As of 2011, there is a beneficial expat regime for
individuals that have not been resident of Portugal
for the past five years. Under this regime, employment
and self-employment income will be taxed at the flat
rate of 20%, withheld at source. In addition,
expats will not be subject to tax on overseas income,
providing that income is subject to tax (even if
effectively taxed at 0%) and the income
was not earned in a black listed country.
Income tax
Progressive up to 48%, plus a surcharge of 3.5% and an additional tax up to 5%
for income in excess of €80,000 (maximum total tax can reach 56.5%). The
Portuguese employers are obliged to withhold tax advances and social security
contribution on personal salary and provide the proper authorities with these
amounts. The tax year is the calendar year. The deadline for submitting a tax
return expires on 31st March of the following year or on 31th April if submitted
via website.
51
Double Tax Treaty – Portugal
Income from employment may be
taxed in Portugal. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Polish Expat
is neither a resident of Portugal nor
has a permanent establishment or
fixed base in Portugal.
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Portugal,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Portuguese Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Portuguese Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Portuguese
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Portugal derives income which
may be taxed in Poland, Portugal
shall allow as a deduction from
the Portuguese tax of that person,
an amount equal to the Polish tax
paid under Polish law, as computed
by reference to the same income
to which the Portuguese tax is
computed.
52
Romania
Polish Expats in Romania
In Romania, non-residents pay tax only on income earned on the territory
of Romania.
Double Tax Treaty – Romania
Income from employment may be taxed
in Romania. Tax exemption applies if
the following conditions are
jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in the calendar year concerned, and
• The employer of the Polish Expat is neither
a resident of Romania nor has a permanent establishment or fixed base in
Romania.
Income tax
Individuals are taxed on all remuneration (including benefits in kind)
for duties performed in Romania, on a flat rate of 16%. The Romanian
employers are obliged to withhold, declare and pay the income tax and
social security contributions to the proper authorities. Employees are not
obliged to submit an annual tax return.
53
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Romania,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Romanian Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Romanian Expat
does not exceed in the aggregate
183 days in the calendar year
concerned, and
• The employer of the Romanian
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Romania derives income which
may be taxed in Poland, Romania
shall allow as a deduction from
the Romanian tax of that person,
an amount equal to the Polish tax
paid under Polish law, as computed
by reference to the same income
to which the Romanian tax is
computed.
54
Slovakia
Polish Expats in Slovakia
No special tax regime for expatriates. There are the same tax allowances as
for the tax residents. However, spouse tax allowance and a tax bonus for
children are applicable only in cases where at least 90% of the worldwide
income is sourced from Slovakia.
Double Tax Treaty – Slovakia
Income from employment may be taxed in Slovakia. Tax exemption
applies if the following conditions are jointly met:
• The stay of the Polish Expat does not exceed in the aggregate 183 days in
any 12-month period concerned, and
• The employer of the Polish Expat
is neither a resident of Slovakia
nor has a permanent
establishment or fixed
base in Slovakia.
Income tax
19% up to the annual tax base of €35,022.32 (for the year 2014 as well as
2015) and 25% on the tax base exceeding this amount. Individuals are taxed on
all remuneration (including benefits in kind) for duties performed in Slovakia.
The Slovak employers are obliged to withhold income tax and social security
contributions from employees’ remuneration. The tax year is the calendar year.
The deadline for submitting annual tax return expires on 31st of March. The
employees who receive income only from an employment do not have to submit
annual tax return.
55
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Slovakia,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Slovak Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Slovak Expat
does not exceed in the aggregate
183 days in any 12-month period
concerned, and
• The employer of the Slovak Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Slovakia derives income which
may be taxed in Poland, Slovakia
shall allow as a deduction from
the Slovak tax of that person, an
amount equal to the Polish tax paid
under Polish law, as computed by
reference to the same income to
which the Slovak tax is computed.
56
Slovenia
Polish Expats in Slovenia
In Slovenia, non-residents pay tax only on income earned on the territory
of Slovenia.
Double Tax Treaty – Slovenia
Income from employment may be taxed in Slovenia.
Tax exemption applies if the following conditions are jointly met:
• The stay of the Polish Expat does not exceed in the aggregate 183 days
in the calendar year concerned, and
• The employer of the Polish Expat
is neither a resident of Slovenia nor
has a permanent establishment
or fixed base in Slovenia.
Income tax
Individuals are taxed on all remuneration (including benefits in kind) for duties
performed in Slovenia, on a progressive rates 16% - 50% depending on amount
of income. The Slovene employers are obliged to deduct income tax and social
security contributions from employees’ remuneration. The tax year is the
calendar year. The deadline for submitting annual tax return expires on 31st of
July of the year following the income year.
57
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Slovenia,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Slovene Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Slovene Expat
does not exceed in the aggregate
183 days in the calendar year
concerned, and
• The employer of the Slovene
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method – where a resident
of Slovenia derives income which
may be taxed in Poland, Slovenia
shall allow as a deduction from
the Slovene tax of that person, an
amount equal to the Polish tax paid
under Polish law, as computed by
reference to the same income to
which the Slovene tax is computed.
58
Spain
Polish Expats in Spain
Spain has a special regime for expatriates assigned to Spain
as a consequence of an employment contract. Expatriates eligible
for this regime are only taxed on income obtained in Spain,
at a 24% flat rate (the excess over €600,000.00 is taxed at 47%/45%).
Double Tax Treaty – Spain
Income from employment may be taxed in Spain. Tax exemption
applies if the following conditions are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in the financial year, and
• The employer of the Polish Expat
is neither a resident of Spain nor has
a permanent establishment
or fixed base in Spain.
Income tax
Individuals are taxed on all earned income and passive income and rates are
progressive from 20% to 47% for 2015 and 19% to 45% for 2016 and onwards.
Savings income is taxed at 20% to 24% for 2015. Employees pay social security
contributions at 6,35%. But some plain cost has been introduced in specific
cases. The tax year is the calendar year. An annual tax return is to be filled
between 3 May and 30 June of the following year.
59
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Spain,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Spanish Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Spanish Expat
does not exceed in the aggregate
183 days in the financial year, and
• The employer of the Spanish
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
exemption method - where a
resident of Spain derives income
which may be taxed in Poland,
Spain shall exempt such income
from tax. Spain may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
60
Sweden
Income tax
Generally all earnings are taxed as income from employment provided the
income is not considered as business income or income from capital gains.
All transfers from an employer to an employee are taxable as income from
employment, i.e. wages, fees, sickness allowances, severance pay as well as
benefits in kind. Under certain conditions, foreign employees working in Sweden
for a limited period may qualify for a reduction of the income tax liability on
their earnings. The reduction amounts to 25% of taxable income, i.e. 75% of the
income is taxed at ordinary rates and is applicable for only the first three years
as long as the employer/employee applies for a ruling within three months of
the work started in Sweden. The employer has to be Swedish, i.e. an entity
incorporated under Swedish law or a foreign entity
with a permanent establishment for Corporate
Income Tax (CIT) purposes in Sweden.
The employee may not have been a tax
resident in Sweden during the five years
preceding the stay. The intended stay
in Sweden may not exceed five years.
Total taxation consists of a National
Tax and Local Tax varying depending
on income and location and may
exceed 56%. Annual tax returns
must be submitted.
61
Polish Expats in Sweden
Double Tax Treaty – Sweden
Income from employment may be
taxed in Sweden. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Polish Expat
is neither a resident of Sweden nor
has a permanent establishment or
fixed base in Sweden.
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Sweden,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Swedish Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Swedish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Swedish
Expat is neither a resident of Poland
nor has a permanent establishment
or fixed base in Poland.
Elimination of double taxation:
credit method - where a resident of
Sweden derives income which may
be taxed in Poland, Sweden shall
allow as a deduction from the tax
on such income, an amount equal
to the Polish tax paid in respect of
such income.
62
Switzerland
Polish Expats in Switzerland
There are special deductions against taxable income
for expenses such as housing, relocation and schooling costs
unless reimbursed by the employer.
If expatriates are affiliated
to their own social security system,
they are exempt from paying
Swiss social security taxes.
Income tax
Individuals are taxed on all remuneration for duties performed in Switzerland
on a progressive scale typically between 6% and 32% depending on the place of
residence and level of income. All transfers from an employer to an employee
are taxable as income from employment, i.e. wages, fees, sickness allowances,
severance pay as well as benefits in kind. Married person are taxed jointly.
Swiss social security tax of 10.3% is levied on the employee’s salary (50% split
between employer and employee). In addition, mandatory contributions to a
self-funded professional pension plan (i.e. similar to a savings account) as well
as unemployment and accident insurance contributions must be paid.
63
Double Tax Treaty – Switzerland
Income from employment may be
taxed in Switzerland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the tax
year concerned, and
• The employer of the Polish Expat
is neither a resident of Switzerland
nor has a permanent establishment
or fixed base in Switzerland.
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in Switzerland,
Poland shall exempt such income
from tax. Poland may in calculating
the amount of tax on the remaining
income of such resident apply the
rate of tax which would have been
applicable if the exempted income
had not been so exempted.
Swiss Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Switzerland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the Swiss Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the tax
year concerned, and
• The employer of the Swiss Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation:
credit method - where a resident of
Switzerland derives income which
may be taxed in Poland, Switzerland
shall allow as a deduction from
the Swiss tax on such income, an
amount equal to the Polish tax paid
in respect of such income.
64
The United Kingdom
Polish Expats in the United Kingdom
Expatriates from outside the UK may qualify for the ‘remittance basis’
filing option. The remittance basis permits that non UK sourced
investment income or gains will be tax exempted if paid
and retained outside of the UK. Furthermore, non UK
employment duties performed by expatriates in
the first three tax years of residence may also
attract relief. Where the remittance basis
is chosen, certain allowances are not available
and an additional tax charge of GBP 30,000
or GBP 50,000 may apply depending on
how long the expatriate has been resident
in the UK.
For expatriates on temporary assignments
(up to 24 months, to or from the UK),
there are further generous deductions
for travel and subsistence expenses incurred.
Income tax
Broadly, the UK resident individuals are taxed on all remuneration (including
benefits in kind) for duties performed in the UK, on a three tier scale: 20%,
40% and 45%, although the 45% rate only applies to taxable income in excess
of GBP 150,000. There are numerous deductions and exemptions, in particular,
taxable income is determined after deducting a personal tax free allowance
of GBP 10,000 and qualifying pension contributions. Most benefits in kind
are taxable. Employee social security contributions are payable at 12%, with
employers required to pay an additional 13.8% employer
contributions on salaries. Employees using taxpaying system PAYE
(pay as you earn) do not have to submit annual declarations.
65
Double Tax Treaty – the United
Kingdom
Income from employment may be
taxed in the United Kingdom. Tax
exemption applies if the following
conditions are jointly met:
• The stay of the Polish Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the Polish Expat
is neither a resident of United
Kingdom nor has a permanent
establishment or fixed base in the
United Kingdom.
Elimination of double taxation:
exemption method - where a
resident of Poland derives income
which may be taxed in the United
Kingdom, Poland shall exempt
such income from tax. Poland may
in calculating the amount of tax
on the remaining income of such
resident apply the rate of tax which
would have been applicable if the
exempted income had not been so
exempted.
British Expats in Poland
As a rule, income from employment
of natural persons in Poland is
subject to income tax calculated in
compliance with a progressive tax
scale (with rates: 18% and 32%).
Double Tax Treaty – Poland
Income from employment may be
taxed in Poland. Tax exemption
applies if the following conditions
are jointly met:
• The stay of the British Expat
does not exceed in the aggregate
183 days in any 12-month period
commencing or ending in the fiscal
year concerned, and
• The employer of the British Expat
is neither a resident of Poland nor
has a permanent establishment or
fixed base in Poland.
Elimination of double taxation: credit
method – where a resident of the
United Kingdom derives income
which may be taxed in Poland, the
United Kingdom shall allow as a
deduction from British tax of that
person, an amount equal to the
Polish tax paid under Polish law, as
computed by reference to the same
income to which the British tax is
computed.
66
State
Exemption method:
PL resident
Exemption method:
the other state resident
Exemption Tax credit Exemption Tax credit
Austria √ √
Belgium √ √
Bulgaria √ √
Croatia √ √
Cyprus √ √
Czech Republic √ √
Denmark √ √ √
Estonia √ √
Finland √ √
France √ √
Germany √ √
Greece √ √
Hungary √ √
Iceland √ √ √
Ireland √ √
Italy √ √
Latvia √ √
Lithuania √ √
Luxembourg √ √
Malta √ √
Netherlands √ √
Norway √ √
Portugal √ √
Romania √ √
Slovakia √ √
Slovenia √ √
Spain √ √ √
Sweden √ √
Switzerland √ √
United Kingdom √ √
67
Global mobility services in Grant Thornton
The goal of the global mobility
services is to provide comprehensive
support regarding compliance
with statutory obligations imposed
both on foreign nationals deriving
income in Poland and entities
paying out such remuneration
to foreign nationals.
Grant Thornton advisers have
access to the right knowledge and
experience and also necessary tools
ensuring efficient management
throughout the tax year and at
year-end. Ongoing cooperation
with the client makes it possible to
develop structures allowing for tax
optimisation taking into account
the potential risks related to
adopting analysed solutions.
Global mobility services
in Poland include:
Settlements during the tax year
Determining monthly amounts
of withholding tax
•	 Comprehensive advisory
services on payroll, taxes and
social security (Social Insurance
Institution)
•	 Determining fiscal residence of
a foreign national and applying
for certificates of fiscal residence
•	 Analysis of the employment
contract to determine the
income due to a seconded
employee in Poland
•	 Submitting NIP applications
(tax ID number) and/or updates
for the seconded employee and/
or their households
•	 Calculating withholding tax
amounts in a given month
•	 Processing of transfers related
to paycheques and tax
•	 Drawing up statements to
the accountancy department
on total remuneration
Determining the amounts
of social security contributions
•	 Analysis of actual circumstances
to determine whether or not
a given person is subject to
compulsory social security
contributions
•	 Registration and deregistration
for Social Insurance Institution,
as well as reporting changes
in the data of employees,
contractors and the remitter
•	 Calculating monthly social
security contributions, filling
out and submitting monthly
declarations
•	 Processing of transfers
to Social Insurance Institution
68
Drawing up annual tax returns:
•	 related to income from different
forms of employment derived
in Poland and abroad, taking
into account tax reliefs and
exemptions
•	 related to capital gains
•	 related to income from real
estate trading
•	 related to joint tax returns
(of spouses or single parents
with children)
Grant Thornton - a global organization
40,000
employees
over 130
countries
Arkadiusz Łagowski
Manager
Tax Advisor
T +48 22 205 4931
M +48 609 452 377
E arkadiusz.lagowski@pl.gt.com
Katarzyna Ciesielska
Manager
Tax advisor
T +48 61 625 1329
M +48 601 723 540
E katarzyna.ciesielska@pl.gt.com
Find out more about global mobility services!
Małgorzata Samborska
Leader of Global Mobility Services
Tax Advisor
T +48 22 205 4930
M +48 661 538 580
E malgorzata.samborska@pl.gt.com
Visit our website:
http://grantthornton.pl/en/
services/tax-advisory-services/
global-mobility-services/

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EU & EEA Expat Tax Guide: Poland

  • 1. EXPATRIATE TAX GUIDE Taxation of income from employment in the EU & EEA Poland 2016
  • 2. CONTENTS* 2 Austria 4 Belgium 6 Bulgaria 8 Croatia 10 Cyprus 12 Czech Republic 14 Denmark 16 Estonia 18 Finland 20 France 22 Germany 24 Greece 26 Hungary 28 Iceland 30 Ireland 32 Italy 34 Latvia 36 Lithuania 38 Luxembourg 40 Malta 42 Netherlands 44 Norway 46 Poland 50 Portugal 52 Romania 54 Slovakia 56 Slovenia 58 Spain 60 Sweden 62 Switzerland 64 United Kingdom 67 Global Mobility Services in GT Poland Grant Thornton cannot guarantee the accuracy, timeliness or completeness of the data contained herein. As such, you should not act on the information without first seeking professional tax advice from one of the contacts at the rear of the publication. *Poland and Lichtenstein have not conducted a double tax treaty so the latter is excluded from this guidance
  • 3. 1 Introduction Many companies located in the European Union & European Economic Area member states are choosing to post their employees to perform work in the territory of other countries, which places them under obligation to apply certain laws within those countries. The issue of labor income taxation is cumbersome since it requires analysis of the international tax treaties as well as domestic laws of involved in each state, especially methods of eliminating double taxation, social security contributions, tax return filing, items of salary being subject to taxation etc. Let us present pragmatic advice concerning these issues. We hope you will find this guide useful while assessing whether posting employees is advantageous for your company. Should you need any further information or assistant, please do not hesitate to contact us. Małgorzata Samborska Leader of Global Mobility Services Tax Advisor
  • 4. 2 Austria Polish Expats in Austria An Austrian tax charge arises on employment income derived from duties performed in Austria. There are specific expenses deductible from this income to the extent that the individual is employed in Austria. Double Tax Treaty – Austria Income from employment may be taxed in Austria. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Austria nor has a permanent establishment or fixed base in Austria. Income tax Progressive, up to 50% (in addition to high social security costs although these are capped at earnings of €60 000.00 per annum). An employed person is subject to income tax on wages, allowances and all benefits received from employment. The tax year in Austria is the calendar year. The annual tax return must be filed by 30th of April. Married couple are taxed separately, not jointly.
  • 5. 3 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Austria, Poland shall exempt such income from the Polish tax. Nevertheless, Poland may in calculating the amount of Polish tax on the remaining income of such resident, take into account the exempted income or capital. Austrian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Austria. Tax exemption applies if the following conditions are jointly met: • The stay of the Austrian Expat does not exceed in the aggregate 183 days in the fiscal year concerned, and • The employer of the Austrian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of Austria derives income which may be taxed in Poland, Austria shall exempt such income from tax. Nevertheless, Austria may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 6. 4 Belgium Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Belgium, on a progressive scale of income tax between 25% and 50% depending on level of income. Local taxes (0% to 10% depending upon the place of residence) are also payable. There are relatively generous deductions available including child care, mortgage payments and related insurance premiums. Tax credits are also available for pension contributions and life insurance premiums. The tax year in Belgium is the calendar year. The annual tax return must be filed by 30th of June. Polish Expats in Belgium Under certain conditions, a foreign executive assigned temporarily to Belgium within an international group of companies may qualify for a special taxation regime. The executive will be treated for Belgian tax purposes as a nonresident, liable to Belgian personal income tax on his/her Belgian-source income only. The expatriate will not be taxed on supplementary recurring and non-recurring expenses (up to an amount of €11,250 or €29,750 per year) which are incurred as a result of his/her recruitment or transfer to Belgium, whether paid as lump sum allowances or as specific reimbursements of outgoings (i.e. housing allowances, cost of living allowances, tax equalization etc.). In addition to these tax free allowances which can be paid by the employer, the proportion of overall remuneration relating to working days spent abroad on business is excluded from taxable income (the so-called ‘travel exclusion’).
  • 7. 5 Double Tax Treaty – Belgium Income from employment may be taxed in Belgium. Tax exemption applies, if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any twelve-month period commencing or ending in the tax year concerned, and • The employer of the Polish Expat is neither a resident of Belgium nor has a permanent establishment or fixed base in Belgium. Elimination of double taxation: credit method - where a resident of Poland derives income which may be taxed in Belgium, Poland shall allow as a deduction from the Polish tax of that person, an amount equal to the Belgian tax paid under Belgian law, as computed by reference to the same income to which the Polish tax is computed. Belgian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies, if the following conditions are jointly met: • The stay of the Belgian Expat does not exceed in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concerned, and • The employer of the Belgian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of Belgium derives income which may be taxed in Poland, Belgium shall exempt such income from tax. Belgium may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 8. 6 Bulgaria Polish Expats in Bulgaria Every citizen of Poland who works in Bulgaria, in whom there is an obligation in terms of the PIT or insurance, has a duty to register at the relevant Bulgarian tax authorities, in order to obtain an identification number. Income of any kind of premiums, bonuses, benefits in kind, etc., acquired from work in the territory of Bulgaria, beyond the basic salary, is also subject to taxation. If the employment contract is concluded with the Bulgarian employer, he is obliged to calculate and pay monthly income tax payments. In the case of a contract with the employer not established in Bulgaria, the employee should independently calculate and pay monthly advance income tax. Income tax Regardless of the status of tax residence, income from employment is subject to income tax of 10%. Deadline for submission of tax returns and replenishment of any underpaid taxes is 30 April the following year. The tax year in Belgium is the calendar year. Interestingly, the Bulgarian tax authorities provide all sorts of “discount” for taxpayers that make a statement electronically, e.g. if the Bulgarian taxpayers filed tax returns for year 2013 to 5 February 2014, they could count on lowering any shortfall by 5%.
  • 9. 7 Double Tax Treaty – Bulgaria Income from employment may be taxed in Bulgaria. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any twelve-month period, and • The employer of the Polish Expat is neither a resident of Bulgaria nor has a permanent establishment or fixed base in Bulgaria. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Bulgaria, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Bulgarian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Bulgarian Expat does not exceed in the aggregate 183 days in any twelve-month period, and • The employer of the Bulgarian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method – where a resident of Bulgaria derives income which may be taxed in Poland, Bulgaria shall exempt such income from tax. Bulgaria may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 10. 8 Croatia Polish Expats in Croatia Pole acquiring his income from work in the territory of Croatia, beyond the basic salary, is also required for taxation of any kind of premiums, bonuses, benefits in kind, etc. There are some employee benefits that are not taxed to the limit specified by law. If the employment contract is concluded with the Croatian employer, he is obliged to calculate and pay monthly income tax payments. Double Tax Treaty – Croatia Income from employment may be taxed in Croatia. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the calendar year, and • The employer of the Polish Expat is neither a resident of Croatia nor has a permanent establishment or fixed base in Croatia. Income tax Croatian tax system has a progressive scale for income tax from individuals. The scale consists of three thresholds of 12%, 25% and 40% and depends on the amount of income. In addition to the basic income tax, Croatian tax system also provides tax equalization, the amount of which depends on the municipality, which is inhabited by the taxpayer. Deadline for submission of tax returns and payment of any back taxes is end of February of the following year.
  • 11. 9 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Croatia, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Croatian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Croatian Expat does not exceed in the aggregate 183 days in the calendar year, and • The employer of the Croatian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Croatia derives income which may be taxed in Poland, Croatia shall allow as a deduction from the Croatian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Croatian tax is computed.
  • 12. 10 Cyprus Polish Expats in Cyprus Expatriates are entitled to an income tax exemption for the lower of 20% of emoluments and €8,550 per annum for the first three years of employment in Cyprus. Expatriates earning over €100,000 per annum are entitled to a 50% exemption for a period of up to five years. Double Tax Treaty – Cyprus Income from employment may be taxed in Cyprus. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any twelve-month period, and • The employer of the Polish Expat is neither a resident of Cyprus nor has a permanent establishment or fixed base in Cyprus. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Cyprus, on a progressive scale from 0% to 35%. Various personal expenses are allowed as a deduction for tax purposes including life insurance premiums, social insurance contributions, approved provident fund contributions, approved medical scheme contributions. The tax year in Cyprus is the calendar year. The annual tax return must be filed by 30th of April or 31 July (if submitted through TAXISnet) in the following tax year.
  • 13. 11 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Cyprus, Poland shall exempt such income from tax. Nevertheless, in calculating the amount of tax on the remaining income of such resident, Poland may take into account the exempted income. Cypriot Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Cypriot Expat does not exceed in the aggregate 183 days in any 12-month period, and • The employer of the Cypriot Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Cyprus derives income which may be taxed in Poland, Cyprus shall allow as a deduction from the Cypriot tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Cypriot tax is computed.
  • 14. 12 The Czech Republic Polish Expats in the Czech Republic A Czech tax charge arises on employment income derived from duties performed in the Czech Republic based on the gross salary plus social and health insurance paid by the employer. Assessable employment income includes all wages, salaries, overtime pay, bonuses, gratuities, perquisites, benefits etc. including the reimbursement of travel expenses over a certain level. There are no specific concessions for expatriates. Double Tax Treaty – the Czech Republic Income from employment may be taxed in the Czech Republic.Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period, and • The employer of the Polish Expat is neither a resident of the Czech Republic nor has a permanent establishment or fixed base in the Czech Republic. Income tax rate Resident individuals are subject to flat personal income tax rate of 15%. Solidary tax increase of 7% for income exceeding the amount of the average wage announced by the Czech social insurance authorities multiplied by 48 (i.e. exceeding the amount of approx. €45,446 in 2014). The tax year in the Czech Republic is the calendar year. The annual tax return must be filed by 1st of April. Married couple are taxed separately, not jointly.
  • 15. 13 Elimination of double taxation: exemption method – where a resident of Poland derives income which may be taxed in the Czech Republic, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Czech Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Czech Expat does not exceed in the aggregate 183 days in any 12 – month period concerned, and • The employer of the Czech Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - the Czech Republic when imposing taxes on its residents may include in the tax base income which may also be taxed in Poland, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Poland. Such deduction shall not, however, exceed that part of the Czech Republic tax, as computed before the deduction is given, which is appropriate to the income which may be taxed in Poland.
  • 16. 14 Denmark Polish Expats in Denmark Foreign key employees working temporarily in Denmark, who have not been subject to Danish taxation (on certain income) in the previous 10 years, may choose to be taxed at a flat rate of 26% of their gross salary plus a labour market contribution of 8%, resulting in a total tax of approximately 32% of their gross salary (for up to 60 months). Certain requirements must be met in order to qualify for the expat regime. Double Tax Treaty – Denmark Income from employment may be taxed in Denmark. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Denmark nor has a permanent establishment or fixed base in Denmark. Income tax Progressive up to 51,95%. The Danish tax rates are among the highest in Europe. The Danish tax system, however, provides a number of reliefs and exemptions that reduce the tax base. The tax year coincides with the calendar year, and the deadline for filing a tax return is 1st of July of the following year. In Denmark, there are two tax-free amounts - one limit shall apply to persons under 18 years of age, while the second: persons over 18 years of age.
  • 17. 15 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Denmark, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Danish Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Danish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Danish Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Denmark derives income which may be taxed in Poland, Denmark shall allow as a deduction from the Danish tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Danish tax is computed.
  • 18. 16 Estonia Polish Expats in Estonia No special favorable tax regime for expatriates. Non-residents pay tax only on their income received from Estonian sources. Rules for the calculation and payment of monthly advances and the right to benefit from tax relief for non-residents is just as for tax residents. Double Tax Treaty – Estonia Income from employment may be taxed in Estonia. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Estonia nor has a permanent establishment or fixed base in Estonia. Income tax The tax rate for 2015 is 20% of the taxable income. The tax year coincides with the calendar year. The deadline for submitting a tax return expires on 31st March of the following year. Estonian tax system provides many tax reliefs and exemptions that reduce the tax base, these include, among others, a joint settlement with the spouse. In addition to tax relief, tax residents of Estonia can count on many exemptions for benefits in kind - many of them are not subject to PIT.
  • 19. 17 Elimination of double taxation: exemption method – where a resident of Poland derives income which may be taxed in the Estonia, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Estonian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Estonian Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Estonian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Estonia derives income which may be taxed in Poland, Estonia shall allow as a deduction from the Estonian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Danish tax is computed.
  • 20. 18 Finland Polish Expats in Finland A Finnish tax charge arises on employment income derived from duties performed in Finland. Assessable employment income includes all wages, salaries, overtime pay, bonuses, gratuities, perquisites, benefits etc. There are no specific expatriate concessions in Finland. Double Tax Treaty – Finland Income from employment may be taxed in Finland. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the calendar year concerned, and • The employer of the Polish Expat is neither a resident of Finland nor has a permanent establishment or fixed base in Finland. Income tax Finnish tax system has a progressive scale for income tax from individuals. The scale consists of five tax thresholds: 6.5%, 17.5%, 21.5%, 29.75% and 31.75% and depends on the amount of income. In addition to basic income, Finnish tax system also provides for a municipal tax, the amount of which depends on the municipality, which is inhabited by the taxpayer. Interestingly, people who are members of churches of the Evangelical-Lutheran or Orthodox, are obliged to pay a tax of 1-2% of income. The tax year coincides with the calendar year. Married couple are taxed separately, not jointly.
  • 21. 19 Elimination of double taxation: exemption method – where a resident of Poland derives income which may be taxed in Finland, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Finnish Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Finland. Tax exemption applies if the following conditions are jointly met: • The stay of the Finnish Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Finnish Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Finland derives income which may be taxed in Poland, Finland shall allow as a deduction from the Finnish tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Finnish tax is computed.
  • 22. 20 France Polish Expats in France A French tax liability arises on income derived from duties performed in France. For new residents seconded to France (impatriates), allowances related to secondment and remuneration related to workdays spent out of France are tax exempt, under certain conditions. Double Tax Treaty – France Income from employment is taxed in France. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the tax year, and • The employer of the Polish Expat is neither a resident of France nor has a permanent establishment or fixed base in France. Income tax French tax system has a progressive scale for income tax from individuals. The scale consists of four tax threshold: 14%, 30%, 41 and 45% and depends on the amount of income. An employed person is subject to income tax on wages, allowances and benefits in kind received from employment (for example company car used for private purposes). The taxable base depends on members of family – for example; if a married couple have one child their taxable income is divided into 3. The tax year is the calendar year. Married persons must file annual tax return jointly, not separately. Filing a tax return is mandatory before end of May (end of June if filing online).
  • 23. 21 Elimination of double taxation: exemption method – where a resident of Poland derives income which may be taxed in France, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. French Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment is taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the French Expat does not exceed in the aggregate 183 days in the fiscal year, and • The employer of the French Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of France derives income which may be taxed in Poland under rules of Double Tax Treaty, France shall exempt such income from tax. France may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 24. 22 Germany Polish Expats in Germany No special expatriate regime. In general, individual taxpayers are allowed to claim all expenses directly incurred with their income from employment. There is a tax free lump sum for these expenses for employees at an amount of €1,000. Thereafter, various other deductions and allowances apply on taxable income. Double Tax Treaty – Germany Income from employment may be taxed in Germany. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the tax year concerned, • The employer of the Polish Expat is neither a resident of Germany nor has a permanent establishment or fixed base in Germany. The abovementioned exemption does not apply if: • under employment contract the employee performs services in favour of entity other than the employer, who controls directly or indirectly the manner of exercise of such a performance and • the employer does not bear the responsibility or risk of effect of the employee’s performance Income tax German tax system has a progressive scale for income tax from individuals. Rates are progressive starting at 14% up to 45% and depend on the amount of income. Tax base is different for single and married. Married couples may choose to be assessed either jointly or separately. The tax year is the calendar year. The deadline for submitting a tax return expires on 31st of May of the following year.
  • 25. 23 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Germany, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. German Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the German Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the German Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. The abovementioned exemption does not apply if: • under employment contract the employee performs services in favour of entity other than the employer, who controls directly or indirectly the manner of exercise of such a performance and the employer does not bear the responsibility or risk of effect of the employee’s performance Elimination of double taxation: exemption method - where a resident of Germany derives income which may be taxed in Poland, Germany shall exempt such income from tax. German tax authorities may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 26. 24 Greece Polish Expats in Greece A Greek tax charge arises on employment income derived from duties performed in Greece. Taxable employment income includes all wages, salaries, overtime pay, bonuses, gratuities, perquisites, benefits etc. There is also a requirement on the expatriate’s employer to deduct Greek payroll withholding tax from the taxable employment income. There are no specific expatriate concessions in Greece. Double Tax Treaty – Greece Income from employment may be taxed in Greece. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in calendar year concerned, and • The employer of the Polish Expat is neither a resident of Greece nor has a permanent establishment or fixed base in Greece. Income tax Greek tax system has a progressive scale for income tax from individuals. The scale consists of three tax threshold: 22%, 32% and 42% and depends on the amount of income. An individual whose income is only from a wage is not obligated to file an annual return. Greek tax system provides many tax reliefs and exemptions that reduce the tax base. Married couple must file annual tax return jointly, but they are taxed separately.
  • 27. 25 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Greece, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Greek Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Greek Expat does not exceed in the aggregate 183 days in calendar year concerned, and • The employer of the Greek Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Greece derives income which may be taxed in Poland, Greece shall allow as a deduction from the Greek tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Greek tax is computed.
  • 28. 26 Hungary Polish Expats in Hungary Expatriates are subject to Hungarian tax on the portion of income attributable to work in Hungary. Double Tax Treaty – Hungary Income from employment may be taxed in Hungary. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Hungary nor has a permanent establishment or fixed base in Hungary. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed at a rate of 16%. Employers’ social security contributions are payable at 27%. Employees pay 8.5% health and unemployment contribution and 10% pension contribution without limitation. The tax year is the calendar year. The deadline for submitting a tax return expires on 20th May following year. Married couples are taxed separately.
  • 29. 27 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Hungary, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Hungarian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Hungarian Expat does not exceed in the aggregate 183 days in the fiscal year concerned, and • The employer of the Hungarian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of Hungary derives income which may be taxed in Poland, Hungary shall exempt such income from tax. Hungary may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 30. 28 Iceland Polish Expats in Iceland The person who holds a domicile or habitual residence (center of vital interests, leisure activities etc.) in the territory of Iceland is considered as a tax resident in Iceland. As a rule, the expenses concerning an employment incurred by employee are not deductible. However, some kinds of costs related to an accommodation or meals of posted employee may be deductible. Double Tax Treaty – Iceland Income from employment may be taxed in Iceland. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Iceland nor has a permanent establishment or fixed base in Iceland. Income tax Icelandic tax system has three tax rates: 37,13%, 38,35% and 46,25%. An employed person is subject to income tax on wages, allowances and benefits in kind received from employment. The employer is obliged to withhold the part of employee’s salary for the social and health security contributions. The deadline for submitting a tax return expires on the end of March the following year. Married couple are taxed separately.
  • 31. 29 Elimination of double taxation: exemption method – where a resident of Poland derives income which may be taxed in Iceland, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Icelandic Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Icelandic Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Icelandic Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Iceland derives income which may be taxed in Poland, Iceland shall allow as a deduction from the Icelandic tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Icelandic tax is computed.
  • 32. 30 Ireland Polish Expats in Ireland Tax free subsistence payments are possible for secondment in certain circumstances and there are incentives for high paid expatriates. Double Tax Treaty – Ireland Income from employment may be taxed in Ireland. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the fiscal year, and • The employer of the Polish Expat is neither a resident of Ireland nor has a permanent establishment or fixed base in Ireland. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Ireland, on a two tier system of income tax rates starting at 20% up to €33,800 and 40% on income exceeding €33,800. The Irish tax system is similar to British. Just like in the UK, the Irish employers are obliged to withhold so-called PAYE (Pay As You Earn) of the employees’ wages. An employed person is subject to income tax on wages, allowances and benefits in kind received from employment. The tax year is the calendar year. The deadline for submitting a tax return expires on 31st of October. Married couple are taxed jointly or separately.
  • 33. 31 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Ireland, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Irish Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Irish Expat does not exceed in the aggregate 183 days in the fiscal year, and • The employer of the Irish Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Ireland derives income which may be taxed in Poland, Ireland shall allow as a deduction from the Irish tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Irish tax is computed.
  • 34. 32 Italy Polish Expats in Italy There are a few specific concessions for expatriates. Income includes all amounts paid or accrued in a calendar year and paid by 12 January of the following calendar year as salary, wages, commissions, director’s fees, bonuses and taxable benefits. Employment income derived by Italian tax residents who work abroad on a continuous basis for more than 183 days is taxed on a conventional reduced taxable basis. Income tax Italian tax system has a progressive scale for income tax from individuals. The scale consists of five tax thresholds: 23%, 27%, 38%, 41% and 43% and depends on the amount of income. An additional surcharge of 3% applies to income exceeding €300,000. There is also a regional tax of up to 3.33% and a municipal tax of 0.1%-0.9% depending on a region. An employed person is subject to income tax on wages, allowances and benefits in kind received from employment. The tax year is the calendar year. The deadline for submitting a tax return expires on the end of September. Married persons are taxed separately.
  • 35. 33 Double Tax Treaty – Italy Income from employment may be taxed in Italy. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Polish Expat is neither a resident of Italy nor has a permanent establishment or fixed base in Italy. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Italy, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Italian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Italian Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Italian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Italy derives income which may be taxed in Poland, Italy shall allow as a deduction from the Italian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Italian tax is computed.
  • 36. 34 Latvia Polish Expats in Latvia There is no special expatriate tax regime and for tax purposes they are treated as residents. Double Tax Treaty – Latvia Income from employment may be taxed in Latvia. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Latvia nor has a permanent establishment or fixed base in Latvia. Income tax Latvian tax system has a flat rate of 23% for individuals’ income. An employed person is subject to income tax on wages, allowances and benefits in kind received from employment (for example: company’s car usage). The Latvian employers are obliged to withhold tax advances and social security contribution on personal salary and provide the proper authorities with these amounts. The tax year is the calendar year. The deadline for submitting a tax return expires on 1st of June.
  • 37. 35 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Latvia, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Latvian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Latvian Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Latvian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Latvia derives income which may be taxed in Poland, Latvia shall allow as a deduction from the Latvian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Latvian tax is computed.
  • 38. 36 Lithuania Polish Expats in Lithuania Resident individuals are taxed on their worldwide income. Non-residents are subject to Lithuanian tax on income originating in Lithuania. Generally, income or compensations received by an expatriate for both business and private purposes such as cost of living, relocation expenses, settling expenses, schooling allowance are added to the income and taxed accordingly. Double Tax Treaty – Lithuania Income from employment may be taxed in Lithuania. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Lithuania nor has a permanent establishment or fixed base in Lithuania. Income tax The Lithuanian tax system has a flat rate of 15%. An employed person is subject to income tax on wages, allowances and benefits in kind received from employment. The tax year is the calendar year. The deadline for submitting an annual tax return expires on 1st May of the following year.
  • 39. 37 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Lithuania, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Lithuanian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Lithuanian Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Lithuanian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Lithuania derives income which may be taxed in Poland, Lithuania shall allow as a deduction from the Lithuanian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Lithuanian tax is computed.
  • 40. 38 Luxembourg Polish Expats in Luxembourg Since 1st January 2011 there has been a special tax regime for expatriates. The regime only applies to highly skilled expatriates and provides a tax relief in respect of certain relocation expenses incurred. A written application must be submitted to the Luxembourg tax authorities and if the relevant conditions are met the Luxembourg tax authorities will confirm that the regime applies. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Luxembourg, on a progressive scale from 0% to 40%. In addition, a solidarity tax is payable at 7% (or 9% for taxable income exceeding €150,000) of the calculated income tax due. There are general deductions allowable in determining an individual’s taxable income for both business and private purposes such as life assurance and health insurance premiums, childcare costs, loan interest and personal pension contributions. The tax year is the calendar year. The deadline for submitting a tax return expires on 31st of March.
  • 41. 39 Double Tax Treaty – Luxembourg Income from employment may be taxed in Luxembourg. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Polish Expat is neither a resident of Luxembourg nor has a permanent establishment or fixed base in Luxembourg. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Luxembourg, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Luxembourgian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Luxembourgian Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Luxembourgian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of Luxembourg derives income which may be taxed in Poland, Luxembourg shall exempt such income from tax. Luxembourg may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 42. 40 Malta Polish Expats in Malta Expatriates are only taxed in Malta on their Maltese-sourced and remitted income. Foreign gains remitted to Malta are not taxable in Malta. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Malta, on a progressive scale from 15% to 35%. Highly qualified non-Malta domiciled individuals employed in an eligible office within a company that is licensed and/ or recognized by the Malta Financial Services Authority, the Lotteries and Gaming Authority or the Transport Authority, having an annual income in excess of €75,000, may benefit from a flat personal tax rate of 15%. The same principle applies for individuals engaged in the development of innovative and creative digital products occupying specific designations and having minimum income of €45,000. Furthermore, this 15% flat personal tax status is also available for high net worth individuals (subject to certain conditions being satisfied) applicable on foreign income remitted to Malta subject to a minimum annual amount of €20,000 (and €2,500 for every dependant) for EU, EEA and Swiss nationals and €15,000 (and €5,000 for every dependant) for non-EU/EEA/Swiss nationals, after double taxation relief. A similar programme applicable to retirement planning is in place subject to an annual minimum tax charge of €7,500 on pension income.
  • 43. 41 Double Tax Treaty – Malta Income from employment may be taxed in Malta. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Malta nor has a permanent establishment or fixed base in Malta. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Malta, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Maltese Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Maltese Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Maltese Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Malta derives income which may be taxed in Poland, Malta shall allow as a deduction from the Maltese tax of that person.
  • 44. 42 The Netherlands Polish Expats in the Netherlands The Netherlands has a special tax regime for expatriates, ‘the 30% ruling’. If the employee has specific expertise, has been required from abroad and works for an employer who is a Dutch wage tax-withholding agent, then 30% of gross income may be paid out without being subject to income tax. This results in an effective rate of income tax (and social security contributions) for expatriates of 36.4%. Expatriates may also be entitled to special deductions for relocation related expenses. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in the Netherlands, on a progressive scale up to 52%, inclusive of social security contributions. Generally certain benefits can be provided on a tax efficient basis including child care arrangements, company car, cost of living allowance, schooling, housing, medical expenses, relocation expenses and pension arrangements. The tax year is the calendar year. The deadline for submitting a tax return expires on 1st April of the following year. Married persons are taxed separately.
  • 45. 43 Double Tax Treaty – the Netherlands Income from employment may be taxed in the Netherlands. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of the Netherlands nor has a permanent establishment or fixed base in the Netherlands. Elimination of double taxation: credit method - where a resident of Poland derives income which may be taxed in the Netherlands, Poland shall allow as a deduction from the Polish tax of that person, an amount equal to the Dutch tax paid under Dutch law, as computed by reference to the same income to which the Polish tax is computed. Dutch Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Dutch Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Dutch Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of the Netherlands derives income which may be taxed in Poland, the Netherlands shall exempt such items of income by allowing a reduction of its tax. This reduction shall be computed in conformity with the provisions of Dutch law for the avoidance of double taxation.
  • 46. 44 Norway Polish Expats in Norway Double Tax Treaty – Norway Income from employment may be taxed in Norway. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the tax year concerned, and • The employer of the Polish Expat is neither a resident of Norway nor has a permanent establishment or fixed base in Norway. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Norway, on a progressive scale from 0% to 12%. The taxpayers are also obligated to pay combined national and municipal income tax rated at 24,5%-28% depending on a region. The rate of social security contribution amounts to 7,8%. The Norwegian employers are obliged to withhold tax advances and social security contribution on personal salary and provide the proper authorities with these amounts. The tax year is the calendar year. The deadline for submitting the annual tax return expires on 30th of April in the year following the income year. Married couple may choose to be assessed either jointly or separately.
  • 47. 45 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Norway, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Norwegian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Norwegian Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Norwegian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Norway derives income which may be taxed in Poland, Norway shall allow as a deduction from the Norwegian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Polish tax is computed. This reduction shall be computed in conformity with the provisions of Norway law for the avoidance of double taxation.
  • 48. 46 Poland Individuals Taxation in Poland depends upon the residence status of the individual. • Non-residents pay tax only on Polish sourced income. • Residents pay tax on their worldwide income (from both Polish and foreign sources). The tax year for individuals is equal to the calendar year ending on 31 December. Residence An individual person is recognized as having a place of residence on the territory of Poland, if: 1. holds a personal or business interest center (center of vital interest) on the territory of Poland or 2. stays on the territory of Poland more than 183 days in a tax year, unless a relevant Double Taxation Treaty states otherwise. It means that generally the individual who stays in Poland for more than 183 days is treated as a Polish tax resident subject to taxation on his/her worldwide income. However, if the individual is also a resident in another country, he/she shall be deemed to be a resident only of the state with his/her personal and economic relations are closer (center of vital interests).
  • 49. 47 Tax scale 2015 The table shows the tax brackets applicable in 2015 Taxation Base (PLN) In 2015 a tax amounts to: Over Up to 85,528 18% minus the tax reducing amount PLN 556.02 85,528 PLN 14,839.02 + 32% on the surplus over PLN 85,528.00 Taxation of salaries and wages Taxable employment income includes all wages, salaries, overtime pay, bonuses, gratuities, perquisites, benefits in kind etc. Remuneration for work carried out in Poland is treated as Polish-sourced income (no matter where the employer is located). In the case when an employee derives remuneration from a Polish employer being a Polish resident or from a permanent establishment which a foreign enterprise has in Poland, the said employer or permanent establishment is obliged to: • calculate and declare advance payments at 18% or 32% tax rates; • calculate the annual tax settlement for the employee who opts for it (on an official tax form); • prepare information (on an official tax form) about the income derived or tax loss sustained if the employee submits the tax return on his/her own. If the employee receives the remuneration directly from abroad (from the employer who has the place of residence or place of living abroad) he/she is obliged to pay personal income tax in the form of advance payments by himself/ herself. The amount of the advance payment is to be calculated with the 18% tax rate (the taxpayer can also use a 32% tax rate when appropriate). Personal income tax payers may take advantage of a special tax relief for the Polish tax residents who earn certain kinds of income on the territory of foreign countries, where the double taxation is avoided by using the proportional tax credit method (so-called tax abolition relief).
  • 50. 48 Poland Tax deductible costs A deduction of 111.25 PLN per month is available in respect of expenses associated with earning employment income. The deduction amounts to 139.06 PLN per month in case when a taxpayer’s place of permanent or temporary residence is outside the limits of a district where his or her employment’s establishment exists and the taxpayer does not receive a family separation allowance. Those with more than one employment are entitled to an increased deduction up to 1.5 times of the maximum. An annual tax credit of 556.02 PLN is available to all individuals who have a taxable presence in Poland. Healthcare contributions Healthcare contributions (9% of gross income decreased by social security) are deductible from tax up to 7.75% of the assessment base. Social security contributions Social security contributions (also paid abroad) are deductible from the tax base. Child deduction There is also the possibility of benefit from child deductions - available for parents bringing up children (if certain conditions are met) - up to 1,112.04 PLN annually per child (in 2015); 2,224.08 PLN for two children; 4,224.12 PLN for 3 children; 6,924.12 PLN for 4 children and additionally 2,700 for each next child. Monthly advance payments The successive advance payments should be paid on the 20th day of the month following the month when the income was obtained (e.g. for income obtained in September on 20th October). The tax amount for December should be paid when submitting the annual Polish tax return.
  • 51. 49 Tax Returns The tax year in Poland begins on 1st January and ends on 31st December. An individual should submit the annual tax return no later than on 30th April of a year following a given tax year (or before leaving Poland if it appears earlier). Married couple may file a joint return if they have unlimited tax liability and if they are married the entire tax year and have a marital co-ownership during the entire tax year (this scheme is also applicable for non-residents from an EEA member country, obtaining at least 75% of their global income in Poland). A joint tax return also applies to single parents with dependent children. The joint tax return leads to essential tax savings if the other person (spouse or dependent child) does not receive any tax income or the income is low. The Personal Income Tax Act does not apply to revenue which is subject to the provisions on tax on inheritance and donations, actions that cannot be the subject of a legally binding agreement, or revenue subject to tonnage tax.
  • 52. 50 Portugal Polish Expats in Portugal As of 2011, there is a beneficial expat regime for individuals that have not been resident of Portugal for the past five years. Under this regime, employment and self-employment income will be taxed at the flat rate of 20%, withheld at source. In addition, expats will not be subject to tax on overseas income, providing that income is subject to tax (even if effectively taxed at 0%) and the income was not earned in a black listed country. Income tax Progressive up to 48%, plus a surcharge of 3.5% and an additional tax up to 5% for income in excess of €80,000 (maximum total tax can reach 56.5%). The Portuguese employers are obliged to withhold tax advances and social security contribution on personal salary and provide the proper authorities with these amounts. The tax year is the calendar year. The deadline for submitting a tax return expires on 31st March of the following year or on 31th April if submitted via website.
  • 53. 51 Double Tax Treaty – Portugal Income from employment may be taxed in Portugal. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Portugal nor has a permanent establishment or fixed base in Portugal. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Portugal, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Portuguese Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Portuguese Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Portuguese Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Portugal derives income which may be taxed in Poland, Portugal shall allow as a deduction from the Portuguese tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Portuguese tax is computed.
  • 54. 52 Romania Polish Expats in Romania In Romania, non-residents pay tax only on income earned on the territory of Romania. Double Tax Treaty – Romania Income from employment may be taxed in Romania. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Polish Expat is neither a resident of Romania nor has a permanent establishment or fixed base in Romania. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Romania, on a flat rate of 16%. The Romanian employers are obliged to withhold, declare and pay the income tax and social security contributions to the proper authorities. Employees are not obliged to submit an annual tax return.
  • 55. 53 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Romania, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Romanian Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Romanian Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Romanian Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Romania derives income which may be taxed in Poland, Romania shall allow as a deduction from the Romanian tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Romanian tax is computed.
  • 56. 54 Slovakia Polish Expats in Slovakia No special tax regime for expatriates. There are the same tax allowances as for the tax residents. However, spouse tax allowance and a tax bonus for children are applicable only in cases where at least 90% of the worldwide income is sourced from Slovakia. Double Tax Treaty – Slovakia Income from employment may be taxed in Slovakia. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period concerned, and • The employer of the Polish Expat is neither a resident of Slovakia nor has a permanent establishment or fixed base in Slovakia. Income tax 19% up to the annual tax base of €35,022.32 (for the year 2014 as well as 2015) and 25% on the tax base exceeding this amount. Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Slovakia. The Slovak employers are obliged to withhold income tax and social security contributions from employees’ remuneration. The tax year is the calendar year. The deadline for submitting annual tax return expires on 31st of March. The employees who receive income only from an employment do not have to submit annual tax return.
  • 57. 55 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Slovakia, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Slovak Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Slovak Expat does not exceed in the aggregate 183 days in any 12-month period concerned, and • The employer of the Slovak Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Slovakia derives income which may be taxed in Poland, Slovakia shall allow as a deduction from the Slovak tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Slovak tax is computed.
  • 58. 56 Slovenia Polish Expats in Slovenia In Slovenia, non-residents pay tax only on income earned on the territory of Slovenia. Double Tax Treaty – Slovenia Income from employment may be taxed in Slovenia. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Polish Expat is neither a resident of Slovenia nor has a permanent establishment or fixed base in Slovenia. Income tax Individuals are taxed on all remuneration (including benefits in kind) for duties performed in Slovenia, on a progressive rates 16% - 50% depending on amount of income. The Slovene employers are obliged to deduct income tax and social security contributions from employees’ remuneration. The tax year is the calendar year. The deadline for submitting annual tax return expires on 31st of July of the year following the income year.
  • 59. 57 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Slovenia, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Slovene Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Slovene Expat does not exceed in the aggregate 183 days in the calendar year concerned, and • The employer of the Slovene Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of Slovenia derives income which may be taxed in Poland, Slovenia shall allow as a deduction from the Slovene tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the Slovene tax is computed.
  • 60. 58 Spain Polish Expats in Spain Spain has a special regime for expatriates assigned to Spain as a consequence of an employment contract. Expatriates eligible for this regime are only taxed on income obtained in Spain, at a 24% flat rate (the excess over €600,000.00 is taxed at 47%/45%). Double Tax Treaty – Spain Income from employment may be taxed in Spain. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in the financial year, and • The employer of the Polish Expat is neither a resident of Spain nor has a permanent establishment or fixed base in Spain. Income tax Individuals are taxed on all earned income and passive income and rates are progressive from 20% to 47% for 2015 and 19% to 45% for 2016 and onwards. Savings income is taxed at 20% to 24% for 2015. Employees pay social security contributions at 6,35%. But some plain cost has been introduced in specific cases. The tax year is the calendar year. An annual tax return is to be filled between 3 May and 30 June of the following year.
  • 61. 59 Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Spain, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Spanish Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Spanish Expat does not exceed in the aggregate 183 days in the financial year, and • The employer of the Spanish Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: exemption method - where a resident of Spain derives income which may be taxed in Poland, Spain shall exempt such income from tax. Spain may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted.
  • 62. 60 Sweden Income tax Generally all earnings are taxed as income from employment provided the income is not considered as business income or income from capital gains. All transfers from an employer to an employee are taxable as income from employment, i.e. wages, fees, sickness allowances, severance pay as well as benefits in kind. Under certain conditions, foreign employees working in Sweden for a limited period may qualify for a reduction of the income tax liability on their earnings. The reduction amounts to 25% of taxable income, i.e. 75% of the income is taxed at ordinary rates and is applicable for only the first three years as long as the employer/employee applies for a ruling within three months of the work started in Sweden. The employer has to be Swedish, i.e. an entity incorporated under Swedish law or a foreign entity with a permanent establishment for Corporate Income Tax (CIT) purposes in Sweden. The employee may not have been a tax resident in Sweden during the five years preceding the stay. The intended stay in Sweden may not exceed five years. Total taxation consists of a National Tax and Local Tax varying depending on income and location and may exceed 56%. Annual tax returns must be submitted.
  • 63. 61 Polish Expats in Sweden Double Tax Treaty – Sweden Income from employment may be taxed in Sweden. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of Sweden nor has a permanent establishment or fixed base in Sweden. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Sweden, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Swedish Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Swedish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Swedish Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Sweden derives income which may be taxed in Poland, Sweden shall allow as a deduction from the tax on such income, an amount equal to the Polish tax paid in respect of such income.
  • 64. 62 Switzerland Polish Expats in Switzerland There are special deductions against taxable income for expenses such as housing, relocation and schooling costs unless reimbursed by the employer. If expatriates are affiliated to their own social security system, they are exempt from paying Swiss social security taxes. Income tax Individuals are taxed on all remuneration for duties performed in Switzerland on a progressive scale typically between 6% and 32% depending on the place of residence and level of income. All transfers from an employer to an employee are taxable as income from employment, i.e. wages, fees, sickness allowances, severance pay as well as benefits in kind. Married person are taxed jointly. Swiss social security tax of 10.3% is levied on the employee’s salary (50% split between employer and employee). In addition, mandatory contributions to a self-funded professional pension plan (i.e. similar to a savings account) as well as unemployment and accident insurance contributions must be paid.
  • 65. 63 Double Tax Treaty – Switzerland Income from employment may be taxed in Switzerland. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the tax year concerned, and • The employer of the Polish Expat is neither a resident of Switzerland nor has a permanent establishment or fixed base in Switzerland. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in Switzerland, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. Swiss Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Switzerland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the Swiss Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the tax year concerned, and • The employer of the Swiss Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method - where a resident of Switzerland derives income which may be taxed in Poland, Switzerland shall allow as a deduction from the Swiss tax on such income, an amount equal to the Polish tax paid in respect of such income.
  • 66. 64 The United Kingdom Polish Expats in the United Kingdom Expatriates from outside the UK may qualify for the ‘remittance basis’ filing option. The remittance basis permits that non UK sourced investment income or gains will be tax exempted if paid and retained outside of the UK. Furthermore, non UK employment duties performed by expatriates in the first three tax years of residence may also attract relief. Where the remittance basis is chosen, certain allowances are not available and an additional tax charge of GBP 30,000 or GBP 50,000 may apply depending on how long the expatriate has been resident in the UK. For expatriates on temporary assignments (up to 24 months, to or from the UK), there are further generous deductions for travel and subsistence expenses incurred. Income tax Broadly, the UK resident individuals are taxed on all remuneration (including benefits in kind) for duties performed in the UK, on a three tier scale: 20%, 40% and 45%, although the 45% rate only applies to taxable income in excess of GBP 150,000. There are numerous deductions and exemptions, in particular, taxable income is determined after deducting a personal tax free allowance of GBP 10,000 and qualifying pension contributions. Most benefits in kind are taxable. Employee social security contributions are payable at 12%, with employers required to pay an additional 13.8% employer contributions on salaries. Employees using taxpaying system PAYE (pay as you earn) do not have to submit annual declarations.
  • 67. 65 Double Tax Treaty – the United Kingdom Income from employment may be taxed in the United Kingdom. Tax exemption applies if the following conditions are jointly met: • The stay of the Polish Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the Polish Expat is neither a resident of United Kingdom nor has a permanent establishment or fixed base in the United Kingdom. Elimination of double taxation: exemption method - where a resident of Poland derives income which may be taxed in the United Kingdom, Poland shall exempt such income from tax. Poland may in calculating the amount of tax on the remaining income of such resident apply the rate of tax which would have been applicable if the exempted income had not been so exempted. British Expats in Poland As a rule, income from employment of natural persons in Poland is subject to income tax calculated in compliance with a progressive tax scale (with rates: 18% and 32%). Double Tax Treaty – Poland Income from employment may be taxed in Poland. Tax exemption applies if the following conditions are jointly met: • The stay of the British Expat does not exceed in the aggregate 183 days in any 12-month period commencing or ending in the fiscal year concerned, and • The employer of the British Expat is neither a resident of Poland nor has a permanent establishment or fixed base in Poland. Elimination of double taxation: credit method – where a resident of the United Kingdom derives income which may be taxed in Poland, the United Kingdom shall allow as a deduction from British tax of that person, an amount equal to the Polish tax paid under Polish law, as computed by reference to the same income to which the British tax is computed.
  • 68. 66 State Exemption method: PL resident Exemption method: the other state resident Exemption Tax credit Exemption Tax credit Austria √ √ Belgium √ √ Bulgaria √ √ Croatia √ √ Cyprus √ √ Czech Republic √ √ Denmark √ √ √ Estonia √ √ Finland √ √ France √ √ Germany √ √ Greece √ √ Hungary √ √ Iceland √ √ √ Ireland √ √ Italy √ √ Latvia √ √ Lithuania √ √ Luxembourg √ √ Malta √ √ Netherlands √ √ Norway √ √ Portugal √ √ Romania √ √ Slovakia √ √ Slovenia √ √ Spain √ √ √ Sweden √ √ Switzerland √ √ United Kingdom √ √
  • 69. 67 Global mobility services in Grant Thornton The goal of the global mobility services is to provide comprehensive support regarding compliance with statutory obligations imposed both on foreign nationals deriving income in Poland and entities paying out such remuneration to foreign nationals. Grant Thornton advisers have access to the right knowledge and experience and also necessary tools ensuring efficient management throughout the tax year and at year-end. Ongoing cooperation with the client makes it possible to develop structures allowing for tax optimisation taking into account the potential risks related to adopting analysed solutions. Global mobility services in Poland include: Settlements during the tax year Determining monthly amounts of withholding tax • Comprehensive advisory services on payroll, taxes and social security (Social Insurance Institution) • Determining fiscal residence of a foreign national and applying for certificates of fiscal residence • Analysis of the employment contract to determine the income due to a seconded employee in Poland • Submitting NIP applications (tax ID number) and/or updates for the seconded employee and/ or their households • Calculating withholding tax amounts in a given month • Processing of transfers related to paycheques and tax • Drawing up statements to the accountancy department on total remuneration Determining the amounts of social security contributions • Analysis of actual circumstances to determine whether or not a given person is subject to compulsory social security contributions • Registration and deregistration for Social Insurance Institution, as well as reporting changes in the data of employees, contractors and the remitter • Calculating monthly social security contributions, filling out and submitting monthly declarations • Processing of transfers to Social Insurance Institution
  • 70. 68 Drawing up annual tax returns: • related to income from different forms of employment derived in Poland and abroad, taking into account tax reliefs and exemptions • related to capital gains • related to income from real estate trading • related to joint tax returns (of spouses or single parents with children) Grant Thornton - a global organization 40,000 employees over 130 countries
  • 71. Arkadiusz Łagowski Manager Tax Advisor T +48 22 205 4931 M +48 609 452 377 E arkadiusz.lagowski@pl.gt.com Katarzyna Ciesielska Manager Tax advisor T +48 61 625 1329 M +48 601 723 540 E katarzyna.ciesielska@pl.gt.com Find out more about global mobility services! Małgorzata Samborska Leader of Global Mobility Services Tax Advisor T +48 22 205 4930 M +48 661 538 580 E malgorzata.samborska@pl.gt.com Visit our website: http://grantthornton.pl/en/ services/tax-advisory-services/ global-mobility-services/