Specjalne strefy ekonomiczne (SEZs)

Tax benefits from business activities within Special Economic Zone (SEZ)

Special Economic Zones (SEZs) are designated areas within the territory of Poland, in which business activities (manufacturing and services) can be conducted on preferential terms.

Companies that invest and conduct business in SEZs in Poland are entitled to benefit from CIT exemptions. Range of the exemption includes the income from the activities conducted on the territory of ZES based on the obtained permission.

Special Economic Zones in Poland

The main objective of creating SEZs in Poland has been to accelerate the economic growth of underdeveloped regions, areas with a high unemployment rate and areas under restructuring. There are 14 SEZs in Poland and each of them consists of a number of subzones.

Special Economic Zones in Poland

1. Kamienna Góra SEZSE, dolnośląskie, wielkopolskie, 367.14;
2. Katowice SEZ, śląskie, małopolskie, opolskie, 2004.83;
3. Kostrzyń-Słubice SEZ, lubuskie, zachodniopomorskie, wielkopolskie, 1454.47;
4. Krakow Technology Park, małopolskie, podkarpackie, 558.72;
5. Legnica SEZ, dolnośląskie, 1059.26;
6. Łódź SEZ, łódzkie, wielkopolskie, mazowieckie, 1276.63;
7. SEZ Euro-Park Mielec, podkarpackie, małopolskie, lubelskie, zachodniopomorskie, 1246.00;
8. Pomeranian SEZ, pomorskie, kujawsko-pomorskie, zachodniopomorskie, wielkopolskie, 1323.23;
9. Słupsk SEZ, pomorskie, zachodniopomorskie, wielkopolskie, 824.35;
10. SEZ Starachowice, świętokrzyskie, mazowieckie, opolskie, łódzkie, lubelskie, 612.91;
11. Suwałki SEZ, podlaskie, warmińsko-mazurskie, mazowieckie, 342.77;
12. Tarnobrzeg SEZ Euro-Park Wisłosan, podkarpackie, mazowieckie, świętokrzyskie, lubelskie, dolnośląskie, 1632.31;
13. Wałbrzych SEZ, dolnośląskie, opolskie, wielkopolskie, lubuskie, 2212.23;
14. Warmia-Mazury SEZ, warmińsko-mazurskie, mazowieckie, 914.51.

SEZs can be found all over the Poland. Their well-developed infrastructure makes them very attractive for domestic and foreign investors. The number of investors in SEZs has soared, especially since the accession of Poland to the European Union.

getsix^® special Services regarding SEZs

1 ‚Step by step’ introduction to SEZ

• Investment analysis of various exemption options in SEZ;
• Indication of the most tax-effective legal and structural form of business activity to be conducted in SEZ;
• Assistance in finding an attractive real estate for the investor’s activity within the area of SEZ;
• Assistance in negotiations with:
• SEZ management;
• Representatives of the Ministry of Economy;
• Representatives of all other state administration bodies in the procedure of obtaining the SEZ permit and other permits required under the administrative law;
• Preparation and verification of the application documentation during the procedure of permit application (i.e. preparation or verification of the business plan);
• Comprehensive assistance and tax advisory, particularly to foreign investors, in all procedures related to the start-up of business activity in Poland, including assistance in all legal and tax actions with respect to registration of the legal entity.

How to manage tax doubts – our current tax advisory

• Establishment of the terms and conditions of conducting the most tax effective business activity within SEZ;
• Pointing out principles that determine effective business activity within and outside SEZ when conducted by the same investor;
• Identification of solutions to the tax problems arising from conducting business in SEZ;
• Establishment or verification of transfer pricing policies related to transactions concluded by one-group entities, in case their business activities are conducted inside and outside SEZ (including also multinational transactions), as well as related to one entity conducting business inside and outside SEZ;
• Optimisation of the tax structure for business activity in case the available public aid limit has been used up, i.e. in the period when company’s income is to be tax exempted;
• Request for changes in the permission.

Binding tax law interpretations

• Monitoring of a current judgment of the tax authorities and the Administrative Courts in range of SEZ;
• Identification of the tax risk areas that might be minimised by the biding tax law interpretations;
• Optimisation of the tax structure confirmed for tax safety of SEZ entities by biding tax law interpretations;
• Comprehensive assistance from the stage of the application preparation up to the moment of obtaining a binding tax law interpretation (including also the litigation stage at the administrative court).

Enlargement of SEZ into private areas

• Preparation of initial opportunities analysis and new investment project eligibility for SEZ enlargement in a chosen area;
• Comprehensive assistance in relation to the SEZ enlargement process both to undeveloped areas (Greenfield projects) and areas where a company already operates;
• Advice as regards amendment of the SEZ permit preceded by analysis of possible solutions to adjust the permit to company needs;
• Support in establishing internal CIT settlements for companies operating within the SEZ and outside.