Polish Investment Zone (PSI): tax relief for new investments

The Polish Investment Zone (Polska Strefa Inwestycji, PSI) is a government state aid programme for companies carrying out new investments. A company that obtains a support decision may be exempt from income tax (CIT or PIT) on income from that investment, up to the granted aid limit.

PSI relief is often called zone support, because decisions are issued by the managers of the special economic zones (SEZ). Unlike the former SEZ model, support is not limited to designated sites: every municipality in Poland is assigned to a zone, to which the application is submitted.

It is not a grant or a competition. The company does not receive money; it uses a tax exemption once it meets the conditions and obtains the support decision. The decision is issued under the Code of Administrative Procedure, with no competition between applicants.

PSI relief is not limited to building from scratch. A new investment can also be the development of a plant that already operates, for example buying new machinery that increases production capacity. A new investment includes, among others:

• setting up a new plant, for example building a production hall,
• increasing the production capacity of an existing plant, for example by buying fixed assets such as machines and production lines,
• diversifying production by introducing products not previously made at the plant,
• a fundamental change in the production process of an existing plant.

The exemption limit equals eligible costs multiplied by the maximum aid intensity. The intensity ranges from 10% to 70% of eligible costs and depends on the location of the investment and the size of the company. The support decision is issued for 12, 14 or 15 years, depending on the location. The maximum values do not apply to everyone: the parameters must be checked for the specific municipality.

Example: a manufacturer invests PLN 5 million in new machinery and a hall extension in a municipality with a 50% aid intensity. The relief limit is then up to PLN 2.5 million of tax exemption, used during the validity of the decision. The actual saving depends on the income from the investment and on meeting the conditions of the decision.

Zone support can be combined with other forms of state aid, within the permitted aid intensity.

The company chooses the basis on which support is calculated:

• Investment expenditure: purchase of land, construction or extension of buildings, machinery and equipment, intangible assets (licences, patents, know-how), as well as rent for a production or warehouse hall and financial leasing of fixed assets.
• Labour costs: two-year labour costs of newly hired employees related to the investment.

The programme is open to micro, small, medium-sized and large companies, Polish and foreign, both new businesses and those expanding their activity. SMEs and business services projects have lower minimum investment thresholds. The programme covers, among others, the activities below, but whether a specific project qualifies depends on its type, location and meeting the criteria:

• industrial production and processing,
• modern business services: shared service centres (SSC), BPO, IT centres, call centres,
• research and development (R&D) and implementing new technologies.

The quantitative criterion is the minimum amount of investment costs. The threshold depends on the location and company size.

The qualitative criteria concern sustainable economic and social development. There are 13 for industrial activity and 12 for services, and depending on the location 4, 5 or 6 of them must be met. Example criteria (not a complete list):

• creating specialised jobs and offering stable employment,
• robotisation and automation of processes within the investment,
• research and development activity,
• supporting vocational education and cooperation with vocational schools,
• business activity with a low negative environmental impact.

The application is submitted to the area manager, i.e. the company managing the special economic zone assigned to the municipality where the investment will be located. The application must be filed before work on the investment starts.

The support decision sets out, among others, the deadline for completing the investment, the amount of eligible costs and the conditions the company must meet to use the exemption.

• Act of 10 May 2018 on supporting new investments (Journal of Laws 2025, item 469).
• Regulation of the Council of Ministers of 27 December 2022 on state aid granted to certain entrepreneurs for new investments (Journal of Laws 2022, item 2861, as amended).
• Regulation of the Minister of Entrepreneurship and Technology of 29 August 2018 on defining areas and assigning them to managers (Journal of Laws 2018, item 1698).