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Changes in CIT for family foundations starting in 2026.

This law amends the Corporate Income Tax (CIT) rules for family foundations, effective January 1, 2026. It limits tax exemptions, for example on rental income from residential properties and on the sale of assets within 36 months of acquisition. As a result, family foundations will now have to pay tax on certain incomes that were previously exempt.
Key points
Family foundations lose CIT exemption on rental income from apartments, unless they rent them out directly for housing purposes.
A 36-month holding period is introduced: selling assets contributed to the foundation before this period ends will be taxable.
New tax rules for loans granted by the foundation to beneficiaries, founders, and related entities.
The new rules on asset sales apply to property contributed to the foundation after December 31, 2025.
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VOTING RESULTS
2025-10-17
For 233
Against 199
Abstain 3
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Status:
Vetoed
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Additional Information
Rządowy projekt ustawy o zmianie ustawy o podatku dochodowym od osób prawnych.
Print number: PROJEKT USTAWY 1753
Process start date: 2025-10-02
Voting date: 2025-10-17
Voting no: 49