The Polish Family Foundation

A tax-efficient holding and succession vehicle — client briefing

For whom: If you own a business, earn passive income, or lease real estate – this could be for you.

What it is. A family foundation (fundacja rodzinna) is a Polish legal entity, in force since 2023, that owns and manages your private wealth. You (the founder) contribute assets; the foundation holds and grows them; your family (the beneficiaries) receive benefits from it. In one structure it combines a low-tax investment holding company, succession planning, and asset protection.

How the tax works — the core advantage

  • 0% tax inside the foundation. Dividends, interest, gains on shares and securities, and long-term residential rental – exempt from CIT.
  • Tax only on pay-out. 15% CIT applies only when the foundation distributes benefits. Retained and reinvested income stays untaxed – so capital compounds.
  • 0% PIT for close family. Benefits to the founder and closest family (spouse, children, grandchildren, parents, siblings) are PIT-exempt; other beneficiaries pay 10% or 15%.
  • No health-insurance contribution (składka zdrowotna) – unlike salary or business income.

The key point: the foundation rewards reinvestment, not full drawdown.

What it is best at

  • Holding shares and receiving dividends from companies
  • Buying and selling securities; participating in investments
  • Leasing real estate on a long-term basis
  • Granting loans

Who it is for

  • Polish tax residents (founder and, ideally, the beneficiaries who will receive distributions).
  • Foreign owners of passive income – rental, securities, dividends, shares in operating companies.
  • Annual income of roughly €100,000 or more – the threshold at which the tax deferred clearly outweighs the running cost.
  • Those who want to grow wealth over years and pass it to the next generation intact.

What it costs

Item Indicative amount
Founding fund — minimum (stays yours, held in the foundation) PLN 100,000
(about EUR 24,000)
Annual accounting & administration ≈ €2,000–5,000
(depending on the scale)
Typical all-in annual running costs ≈ up to €5,000 / year

Rule of thumb: once passive income exceeds about €100k a year, the tax deferred and reinvested comfortably outweighs the ~€5k of annual cost.

It also protects your wealth

  • Asset shielding and creditor-protection features separate personal risk from family capital.
  • Orderly succession, wealth passes to the next generation as beneficiaries who receive defined rights to benefits, without fragmenting the business or portfolio.

Next step

A short call is enough to confirm whether a family foundation fits your situation, followed by a fixed quote for set-up. We handle the full process — statute, notarial deed, court registration, and transfer of assets.

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