Poland's Act of 17 July 2026 broadens its tonnage tax regime to include domestic and offshore-related shipping, expands eligible vessel types, and removes citizenship restrictions for seafarer tax exemptions, with tax provisions effective 1 January 2027 following European Commission approval under Case SA.62692.
Poland has published the Act of 17 July 2026 amending certain laws to support shipping enterprises and create favourable conditions for their operation under the Polish flag.
Signed into law on 7 August 2026, it outlines a 2026 Polish legislative act designed to modernise the maritime sector and incentivise shipping companies to operate under the Polish flag. The Act introduces fundamental changes to the Polish Tonnage Tax Act of 24 August 2006, expanding both its geographic and operational scope. The regulations also introduce tax exemptions for seafarers working on specific vessels within the European Economic Area.
The key amendments to the tonnage tax regime include:
Geographic scope and qualifying activities
The regime’s scope is broadened from traditional international sea transport to include commercial shipping carried out by seagoing vessels between Polish or foreign seaports, as well as between those ports and artificial islands, offshore installations, or other structures located in Polish or foreign maritime areas or on the high seas. This allows domestic and offshore-related shipping activities to qualify.
Expanded fleet and vessel types
In addition to maritime transport, the tonnage tax now covers vessels used for high-seas rescue, pipeline and cable laying, research activities, floating cranes, and the construction or servicing of offshore installations. While high-seas rescue vessels are taxed normally, the Act introduces a specific rule where vessels used for pipeline laying, cable laying, research, floating cranes, and offshore installation servicing are subject to an increased tonnage tax base equal to 130% of the standard base.
Shipping company definition expands
A shipping company now qualifies if it operates vessels under its own name or another’s (including bareboat charters), uses vessels under time or voyage charter arrangements, leases its own vessels on bareboat charter, or manages third-party vessels.
Ship management gets substantial tax reduction
Ship management—defined as technical management (seaworthiness and safety compliance) or crew management (staffing, payroll, insurance, medical care)—receives preferential tonnage tax treatment. Companies performing only technical or only crew management get a 30% tax base reduction. Those performing both functions receive a 50% reduction.
Bareboat charter-outs have strict limits
Bareboat chartering qualifies for tonnage tax only under specific conditions. Charters between companies in the same capital group qualify without restriction. For third-party charters addressing temporary fleet surplus, the arrangement must not exceed 3 years, may not exceed 50% of the company’s net qualifying tonnage, and must be based on documented temporary overcapacity.
EU/EEA link requirements (eligibility & flags)
To qualify, a shipping company must operate from the territory of an EU/EEA Member State. Additionally, more than 50% of its land-based employees (excluding crew on board) must be EU/EEA citizens, and at least 60% of the net tonnage of its fleet must fly an EU/EEA flag. The 60% flag requirement is waived if at least 25% of the company’s net tonnage is registered under an EU/EEA flag at entry, provided the company commits to reaching the 60% threshold within 5 years.
Alternative fuel incentive
In line with environmental goals, vessels powered exclusively by alternative fuels enjoy a reduced tonnage tax base equal to 60% of the standard base.
Seafarer individual income tax (PIT) exemption
The Act heavily restructures the individual income tax exemption for seafarers under the PIT Act of 26 July 1991:
Removal of key restrictions
The amendment removes the highly restrictive requirements that previously required a seafarer to hold EU/EEA citizenship and to work aboard a qualifying vessel for at least 183 days during the tax year. The exemption is now accessible to all qualifying seafarers regardless of nationality or exact days spent at sea, provided they work on vessels flying an EU/EEA flag.
Expanded eligible vessels
The exemption is expanded from transport vessels to also cover seafarers working on vessels utilised for high-seas rescue, pipeline laying, cable laying, research activities, floating cranes, and the construction or servicing of offshore installations.
Strict exclusions and conditions
- Tugboats and dredgers: Work on tugboats and dredgers only qualifies if at least 50% of the vessel’s actual annual operating time is spent on maritime transport (or transport of cargo/passengers for tugboats).
- Non-EU/EEA workers excluded from passenger services relief: Non-EU/EEA seafarers working on vessels providing regular passenger services (including ro-ro ferries) between EU ports remain excluded from the exemption. This exclusion is strictly targeted at non-EU/EEA citizens.
Poland’s tonnage tax scheme received European Commission approval in July 2026 under State aid Case SA.62692 for 10 years. The Act was published on 10 August 2026 and will enter into force on 10 September 2026, though the tax-specific provisions follow a distinct schedule. Both the PIT exemption amendments and the Tonnage Tax Act revisions apply to income derived starting 1 January 2027 and remain effective throughout the Commission’s 10-year approval window.
