Foreigner's taxes · PIT

How a foreigner is taxed in Poland — unlimited vs. limited tax liability

Published: 12 August 2026 · Author: Dariusz Włodarczyk Kancelaria TRC · Reading time: approx. 6 min

Whether you are a resident or a non-resident determines the scope of Polish tax. We explain the difference between unlimited and limited tax liability and what counts as income earned in Poland.

Table of contents
  1. Two types of tax liability
  2. What "income earned in Poland" means
  3. How the tax is calculated
  4. Risk of incorrect classification
  5. Legal basis and sources

1. Two types of tax liability

Polish PIT distinguishes two regimes. Unlimited tax liability (Article 3(1) of the PIT Act) applies to residents — their entire worldwide income is taxed. Limited tax liability (Article 3(2a)) applies to non-residents — only income earned on Polish territory.

2. What "income earned in Poland" means

Article 3(2b) of the PIT Act lists examples of income sources treated as earned in Poland, including work performed on Polish territory (regardless of where the payment is made), business activity conducted in Poland and real property located in Poland. This is an open-ended list.

In practice: a non-resident foreigner physically working in Poland will pay Polish tax on that work, even if the salary is transferred by a foreign entity.

3. How the tax is calculated

Income from employment is as a rule taxed under the tax scale. For certain payments made to non-residents, a flat-rate withholding tax may apply. Whether more favourable rules under a double taxation treaty apply depends, among other things, on a certificate of residence.

4. Risk of incorrect classification

Risk: wrongly assuming a status (resident/non-resident) leads to understated or overstated advance payments and to corrections with interest. Confirm the status at the outset and update it when circumstances change (family arriving, exceeding 183 days).
Show more: what "split-year residence" means

Change of status during the year

So-called "split-year residence" is possible — for part of the year you are a non-resident and for part a resident. Income is then settled separately for each period under the applicable regime. This is typical for people who moved to Poland during a given year.

Not sure what you will be taxed on in Poland?

We will determine your tax status and correctly settle your income — Polish and foreign — taking into account the double taxation treaty.

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Legal notice: this article is for information purposes only and does not constitute legal or tax advice. Legal status: 2026 (Personal Income Tax Act of 26 July 1991, Article 3(1), (2a), (2b)).

Sources: Act of 26 July 1991 on personal income tax, Article 3; ISAP. The above commentary is our own; the provisions cited should be verified against the current text of the act before taking any action.