A government bill (print no. 3148) has been sent to the Sejm that would raise the tax paid by family foundations on payouts from 15% to 19% starting in 2027. For now, it is only a proposal, not binding law.
As Rzeczpospolita (pro.rp.pl) reports, besides the higher rate on every payout from a foundation, the bill provides for taxing the sale of assets contributed to the foundation if the sale takes place within two years. It also aims to close several loopholes through which, according to the bill’s authors, foundations were used as a tool for transactions.
What foundations declared to the tax authorities
Rzeczpospolita cites data from the Ministry of Finance. According to it, 3,017 family foundations filed returns for 2025. The total income on which they paid no tax came to PLN 15.27 billion, and the tax due was declared at PLN 126.8 million. Two-thirds of the exempt income comes from shares in companies, which, as the paper notes, is exactly what the institution was created for.
Another change to the rules
The Family Foundation Act entered into force on 22 May 2023 and was amended even before it began operating. The tax changes were added to it in April 2023 alongside the act on investment funds. According to Rzeczpospolita, a review of the regulations went to consultation in June 2026, and in September the government adopted a new bill. The review still considers a three-stage model: tax when assets are contributed, ongoing taxation of selected income, and the foundation as a PIT payer. Gazeta Prawna also reported the plan to raise the CIT rate on benefits paid by the foundation from 15% to 19%.
The author of the Rzeczpospolita piece assesses that the tightening will affect the loopholes, while the rate increase will affect every foundation. In his view, the tax deferral, the most important benefit, remains untouched. This is the author’s opinion, not the position of the ministry.
What it means
The change concerns family foundations and their beneficiaries, that is, primarily the owners of larger family businesses. The higher rate would apply from 2027, but only if the Sejm passes the bill and the act is signed and published. Until then, the current rules remain in force.
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