The end of Special Economic Zones – what’s next for tax exemptions and the PSI mechanism?

All Special Economic Zone (SSE) permits will expire at the end of 2026. In practice, this means that any unused portion of the tax exemption will be lost, with no possibility of further use after 2026. The coming months are the last opportunity to review tax settlements in terms of how the available tax exemption pool has been used.

At the same time, Poland’s Minister of Finance and Economy is planning amendments to the New Investment Support Act, aimed at adapting the legal framework to the end of the SSE regime and improving the continued use of the PSI (Polish Investment Zone) mechanism.

The draft amendment in this area was published on 8 June 2026. However, its status has remained unchanged since then. We are awaiting further legislative work, particularly as some significant new developments are expected.

Key proposed changes to PSI

As a reminder, the most significant proposed changes to PSI include:

• a proposed departure from the “close connections” concept in determining income exempt from reinvestment,
• the issuance — for certain support decisions — of an opinion by the Head of the National Revenue Administration (KAS) on the data contained in the draft support decision,
• the removal of the employment requirement in the case of robot acquisition.

“For now, we are waiting for further work on the act and the final wording of the new conditions for conducting tax-exempt activity. We are, of course, monitoring the status of the draft on an ongoing basis and will keep clients updated on its progress” — comments Łukasz Łebski, Director of the Tax Reliefs and Incentives team at Thedy & Partners.

Check how the changes will affect your business

Do you have questions about how the end of the SSE regime will affect your company? Considering an investment under the new support conditions? Get in touch with us.

Contact: Łukasz Łebski – lukasz.lebski@thedy.pl