Poland: Restrictions on Intra-Corporate Transfers Forthcoming

Effective May 1, 2025, Poland will enforce stricter intra-corporate transfer (ICT) regulations, impacting multinational companies and their employees. These new rules introduce additional requirements for qualifying transfers, potentially affecting corporate structures and work permit applications.

Key Changes to Intra-Corporate Transfers in Poland

Poland’s new ICT rules will impose two major requirements:

🔸Corporate Connection Requirement: A shareholding or management link between the transferring and receiving entity will be mandatory.

🔸Business Activity Requirement: The transferring entity must demonstrate active business operations in its home country.

These conditions aim to prevent abuse of ICT rules and ensure that transfers serve legitimate business needs rather than circumvention of standard work permit regulations.

Implications for Employers

These changes could significantly impact multinational businesses operating in Poland:

🔸Review Corporate Structures: Employers may need to reassess ownership and management ties between parent and subsidiary companies.

🔸Advance Work Permit Applications: Companies planning ICTs should submit applications before May 1, 2025, to avoid stricter requirements.

🔸Prepare for Processing Delays: As authorities adjust to the new framework, ICT applications may face longer processing times after the rules take effect.

Frequently Asked Questions

Who will be affected by Poland’s new ICT restrictions?

Multinational companies transferring employees to Poland under ICT permits will need to meet stricter eligibility criteria.

What happens if a company does not meet the new requirements?

If an entity lacks a shareholding or management connection, or if it fails to prove business activity, its ICT applications may be rejected.

Should companies submit ICT applications before May 1, 2025?

Yes, businesses should file ICT permit applications before the new rules take effect to avoid complications.

Will there be delays in processing ICT applications after May 1, 2025?

Yes, as authorities transition to the new system, processing times may increase.

Can companies restructure to comply with the new ICT rules?

Yes, businesses may need to restructure ownership or management ties to align with the new requirements.

What should employers do now to prepare?

Review corporate structures, file ICT applications early, and anticipate delays in application processing.

Employers should act now to minimize disruption and ensure compliance with Poland’s upcoming ICT regulations.

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