Inheritance and Estate Tax in Poland

What is the Polish inheritance and gift tax?

Poland imposes a stand-alone inheritance and gift tax (podatek od spadkow i darowizn) under the Ustawa o podatku od spadkow i darowizn of 28 July 1983 (the Act). The tax is levied on the acquirer — each beneficiary or donee individually — not on the estate as a whole. This beneficiary-level structure means siblings inheriting jointly each file and pay separately, and each may fall into a different effective-rate bracket depending on the taxable value they personally receive. The tax base is the fair market value of acquired property and rights as at the acquisition date, reduced by debts and encumbrances (including mortgages, outstanding bills, and documented funeral expenses for inheritances).

Acquisitions from the same person within the preceding 5 years are aggregated. A gift of PLN 20,000 in 2022 followed by an inheritance of PLN 25,000 in 2025 from the same donor/decedent are combined: the total PLN 45,000 is assessed against the relevant threshold, and any prior tax paid is credited against the new liability. This rolling-5-year aggregation rule prevents threshold fragmentation through staged transfers.

Who pays and which tax group applies?

Every beneficiary is assigned to one of three statutory tax groups (grupy podatkowe) based on their relationship to the donor or decedent. Group membership determines both the tax-free threshold and the progressive rate scale.

Group I (Grupa I) includes the closest legal-family circle: spouse, children, grandchildren, great-grandchildren, parents, grandparents, great-grandparents, siblings, stepchildren, step-parents, parents-in-law, sons-in-law, and daughters-in-law. Group I carries the lowest rates (3-7%) and the highest tax-free threshold.

Group II (Grupa II) covers extended family: descendants of siblings (nephews and nieces), siblings of parents (aunts and uncles), spouses of siblings and siblings of spouses, spouses of stepchildren, and step-grandchildren. Group II rates run 7-12%.

Group III (Grupa III) covers all other acquirers — friends, unrelated individuals, and any person not in Groups I or II. Group III bears the highest rates (12-20%) and the lowest tax-free threshold.

The Ministry of Finance publishes the current rate-and-threshold schedule via the Krajowa Administracja Skarbowa (KAS) portal at podatki.gov.pl. Poland country overview provides a broader fiscal context for residents navigating multiple Polish taxes.

What are the current tax-free thresholds?

With effect from 28 June 2023, the Minister of Finance issued a regulation (Rozporzadzenie) significantly raising the tax-free thresholds from their pre-2023 levels. The current thresholds, unchanged through 2025-2026, are:

Before 28 June 2023, the thresholds were PLN 10,434 (Group I), PLN 7,878 (Group II), and PLN 5,308 (Group III). The 2023 increases — more than tripling the Group I limit and more than tripling Group II — represent the largest single upward revision to these thresholds since the Act's enactment. A pending 2026 amendment (Sejm July 2025, Senate December 2025) introduces procedural reforms but does not alter the monetary thresholds.

The tax is calculated only on the excess above the applicable threshold. A Group I beneficiary receiving property worth PLN 80,000 has a taxable base of PLN 43,880 (PLN 80,000 minus PLN 36,120).

What are the progressive tax rates?

Rates are applied progressively to the taxable base (the amount exceeding the threshold) using the statutory bracket table. All brackets are expressed in PLN and have been in force since the 2023 threshold revision.

Group I rates (closest family, after PLN 36,120 deduction):

• First PLN 11,833 of taxable base: 3%
• PLN 11,833-23,665: PLN 355.05 fixed plus 5% on the excess over PLN 11,833
• Above PLN 23,665: PLN 946.60 fixed plus 7% on the excess over PLN 23,665

Group II rates (extended family, after PLN 27,090 deduction):

• First PLN 11,833 of taxable base: 7%
• PLN 11,833-23,665: PLN 828.40 fixed plus 9% on the excess over PLN 11,833
• Above PLN 23,665: PLN 1,893.30 fixed plus 12% on the excess over PLN 23,665

Group III rates (unrelated, after PLN 5,733 deduction):

• First PLN 11,833 of taxable base: 12%
• PLN 11,833-23,665: PLN 1,420.00 fixed plus 16% on the excess over PLN 11,833
• Above PLN 23,665: PLN 3,313.20 fixed plus 20% on the excess over PLN 23,665

A special flat rate of 7% applies to acquisitions by adverse possession (zasiedzenie). Undisclosed gifts discovered during a tax audit are taxed at the maximum 20% rate regardless of relationship group.

What is Grupa Zero and how does the total exemption work?

The most consequential provision of the Act for the majority of Polish family transfers is the total exemption for the innermost family circle, colloquially called Grupa Zero (Group Zero). Grupa Zero is not a formally defined term in the legislation but refers to the exemption created by Article 4a of the Act, which operates inside Group I.

Grupa Zero beneficiaries are: spouse, children (also adopted), grandchildren, great-grandchildren, parents, grandparents, great-grandparents, siblings, stepchildren, step-parents, and foster children (the last-named added by a 2020 amendment). Persons in Grupa Zero owe zero tax on inheritances and gifts of any value from these same relatives, subject to one critical procedural condition: they must report the acquisition to the Urzad Skarbowy (local tax office) on form SD-Z2 (Zgloszenie o nabyciu wlasnosci rzeczy lub praw majatkowych) within six months of the tax obligation arising.

For gifts, the tax obligation arises on the date of the gift. For inheritances, it arises on the date the court ruling confirming the inheritance becomes final (or the date of registration of a notarial inheritance certificate). Under the January 2026 amendment, where a beneficiary can demonstrate the SD-Z2 deadline was missed through no fault of their own — illness, genuine ignorance of the obligation, or administrative error — they may apply to have the deadline reinstated (przywrocenie terminu). Previously, missing the six-month window automatically forfeited the exemption with no recourse, reverting the transfer to Group I rates.

If no SD-Z2 is filed and no reinstatement is granted, the acquisition is taxed under the standard Group I progressive schedule (3-7% above PLN 36,120). For high-value family transfers this can mean a material tax liability that was entirely avoidable by timely filing. The six-month SD-Z2 deadline is one of the most operationally significant compliance requirements in the Polish inheritance tax framework.

When a gift or inheritance is formalised by notarial deed, the notary submits the notification on the beneficiary's behalf — no separate SD-Z2 is required. The filing obligation falls solely on the beneficiary in non-notarised transfers (informal gifts, court-confirmed inheritances not involving a notary).

What filing obligations apply to taxable transfers?

For transfers outside Grupa Zero (Group I, II, and III taxable acquisitions), the beneficiary must file form SD-3 (Zeznanie podatkowe o nabyciu rzeczy lub praw majatkowych) with the competent Urzad Skarbowy within one month of the tax obligation arising. The tax authority issues a formal decision (decyzja) setting the tax amount, and the beneficiary pays within 14 days of receiving that decision.

For Grupa Zero and Group I acquisitions where value is below the PLN 36,120 threshold, no filing is required unless the Urzad Skarbowy requests documentation. The SD-Z2 exemption claim is free of charge and can be submitted electronically via the e-Deklaracje platform or in paper form.

A qualified Polish tax professional familiar with the Ustawa o podatku od spadkow i darowizn can assist with the SD-Z2 filing, SD-3 completion, multi-jurisdiction inherited estates, and the interaction between inheritance tax and the PIT capital-gains framework on subsequently disposed assets. Browse verified professionals via the Poland country overview directory or contact a qualified tax professional in your region for guidance specific to your circumstances.