In June 2026 the government published a draft review of the rules governing the Polish family foundation, summarising the first three years since they took effect. It signals a significant overhaul that every founder and beneficiary should be aware of.
Key directions:
- a redesign of the tax model, moving away from a full exemption towards a preference tied to a genuine succession purpose,
- current taxation of income from business activity, lease, rental and financial income,
- a tax under consideration already at the stage of contributing assets to the foundation,
- a catalogue of arrangements treated as abuse of the structure, alongside growing scrutiny by the tax administration,
- migration of the register to an online system and broader access of tax authorities to its data,
- a question over the succession purpose where the founder is the sole beneficiary.
Some proposals are directional only, and the key tightening package remains pending re-examination. This is therefore not yet binding law, but a clear signal as to the future of the institution.
A full, concise overview of all the proposed changes, together with a practical checklist of what to verify in an existing structure, is available on the PLA.partners blog:
Review of the Polish Family Foundation Act: changes and taxation
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