Poland built a better FIG than the UK, then priced its tax regime wrong

One of my unexpected passions lately has been taxation of financial assets — not because I love tax codes, but because I care about dynamic economies. A number of accomplished people I know are thinking about moving to Poland, and the tax system turns out to be a mundane, yet surprisingly important, part of that decision.

Sadly, the current Polish system is unfriendly to people from places like Silicon Valley or London who have non-trivial financial portfolios. I’m thinking about anyone who was generously compensated with startup equity or who did a fair amount of angel investing. These are exactly the people any country should want to attract: they bring ambition, dynamism, and hard-earned experience.

The complexity problem

The core problem: it’s prohibitively difficult to “import” financial assets when you move your tax residency to Poland.

If all you hold are public stocks, the system is relatively painless and mid-range in terms of taxation. But if you want to attract top talent from Silicon Valley, you need a system that can digest:

• multiple types of stock options and RSUs,
• pre-IPO derivatives (like prepaid variable forward contracts),
• various financing structures built around the trend of companies staying private for longer.

This stuff is complex. And the issue is not theoretical: it can easily take months of tax advisors’ and lawyers’ bespoke and expensive work to figure out if and how you can map a specific portfolio to Polish rules. In many cases, you might end up paying more in legal fees and sunk time than in actual capital gain taxes. If you are truly unlucky, you might run into an edge case where Polish rules accidentally overreach and you end up with a combined effective tax rate north of 70%; I’m aware of one such unfortunate, real case.

One top-tier professional I know was moving from the US back to Europe and seriously considered Warsaw as a base. After learning about the tax complexity around their (very normal, by Silicon Valley standards) equity and financing structures, they dropped Poland from the list. London is now on the shortlist.

For a country that wants to attract this kind of person, that’s a pretty expensive own goal.

Two ways to deal with messy foreign assets

If you care about bringing top talent to Poland, there are basically two paths:

1. Patch the tax code forever.

Keep expanding Polish tax law to explicitly recognize every exotic foreign instrument you encounter. For a mid-sized country, that’s a losing game. You’ll always be chasing the next edge case you didn’t anticipate.

1. Do what the UK did and step out of the game.

The UK’s new Foreign Income and Gains (FIG) regime, from April 2025, takes a different approach: it simply excludes foreign income and gains from taxation for the first four tax years after you become a UK tax resident (subject to qualifying conditions), with no annual fee. The bet is simple: if you make moving tax residency frictionless for high-net-worth individuals, you’ll earn more in the long run from what they build and spend locally than from taxing their Apple shares or pre-IPO stock options.

If moving is too painful, people ignore all other great benefits a country offers and often either stay in the US, or choose places like the UAE.

Poland quietly built a parallel regime

Here’s the curious part: Poland already introduced a parallel tax system back in 2022 that looks a lot like a Polish FIG.

It’s a special “lump sum on foreign income” regime (ryczałt od przychodów zagranicznych) for new residents. In broad strokes:

• You can use it for up to 10 consecutive tax years (vs four in the UK).
• You pay a fixed 200k PLN per year in tax on your foreign income and gains.
• On top of that, you are required to spend at least 100k PLN per year on specified “good causes” in Poland (a built-in philanthropic tithe).
• Minimal reporting — no itemization required, just pay the lump sum.

On paper, this is almost better than the UK’s regime:

• Longer duration (10 vs 4 years).
• Simpler reporting.
• A philanthropic component that channels money into local development.

Poland built the bones of a world-competitive regime — and then made two design choices that almost completely undercut it.

Where the design goes wrong

1. The price point is miscalibrated.

The regime costs 300k PLN per year in total — roughly 75k USD at current exchange rates — whether or not you have any foreign income that year.

At a 19% capital gains rate, you need around 1.6M PLN (~400k USD) of foreign gains a year just to break even.

Realistically, that makes sense only if:

• you expect a very large, fairly imminent liquidity event, or
• you’re in the $3m+ net-worth bracket with significant expected appreciation.

But the people I’m most interested in are the “successful tech workers” and early employees in the $500k–$2m net-worth band with messy, illiquid portfolios. For them, 75k USD/year is simply too steep. They’ll choose London, Dubai, or not move.

2. The regime is invisible and unbranded.

This whole thing was bolted onto the 2022 tax reform and tucked into Chapter 6b of the Polish PIT Act:

• no official, memorable name,
• no dedicated landing page,
• no public narrative that says: “This exists to attract founders, operators and investors to Poland.”

Contrast that with the UK: they have a clearly named regime (“FIG”), an online manual written in human-readable language, and a clear policy story behind it.

In Poland, the lump-sum regime reads more like a technical footnote than a flagship program - or worse, like a suspicious scheme introduced for doubtful reasons. Nobody I’ve talked to understands the rationale — a high annual “subscription” price paired with 10-year availability is an odd design choice. Unsurprisingly, tax attorneys I’ve spoken to are skeptical about recommending it; it doesn’t feel like a stable, deliberate pillar of policy.

Two surgical fixes

The good news is that Poland is already ~70% of the way there. With two fairly small but deliberate changes, this could become one of the most attractive regimes in Europe.

1. Reset the price to a realistic level.

Drop the 200,000 PLN “tax” component and keep only the 100k PLN/year philanthropic tithe (~25k USD). That immediately makes it viable for people with $1m+ in assets who expect meaningful upside but can’t justify 75k/year just to stay in the system.

2. Name it, explain it, own it.

Give the regime:

• an official name (e.g. “Polish Foreign Income Regime” or something sharper),
• a dedicated, English-friendly website explaining how it works,
• an explicit policy rationale: this exists to attract founders, senior operators, and investors who bring capital, skills, and new ventures to Poland.

In other words: turn it from a hidden chapter of the PIT Act treated with suspicion into a visible, intentional part of the country’s economic strategy.

Why this matters

I’m not a tax lawyer but I’m looking at this with an entrepreneurial lens.

Poland already has the structural elements of a very competitive tax regime for importing ambitious people with messy portfolios. It just needs:

• a sensible price point, and
• a story.

Do that, and suddenly Warsaw can compete credibly with London, not just on lifestyle and operating costs, but on the boring—but crucial—question of “what happens to my cap table if I move?”.