Lump-sum tax for managers is an issue that keeps returning in tax practice. In February 2026, Prawo.pl described the risks connected with combining management functions with the provision of services to one’s own company, and the article quoted dr Piotr Sekulski several times. This is another chapter of a problem we had already discussed earlier on the Outsourced.pl blog.
Lump-sum tax for managers – where the risk appears today
In practice, one of the more problematic areas remains a situation where the same person acts in a company in a dual role – as a management board member, manager or shareholder, while at the same time acting as an entrepreneur issuing invoices for additional services. These are exactly the types of models that have been attracting increasing attention from the tax authorities for quite some time. We have already pointed out that a particularly significant risk concerns intangible services, where it is difficult to separate management activities from other business activities.
The issue of lump-sum tax for managers also returned in our commentary forPrawo.pl.
dr Piotr Sekulski, tax advisor
If, therefore, a given person acts in a company in a dual role and combines management with the provision of services taxed under the lump-sum regime, they risk a dispute with the tax authorities. For some time now, the National Revenue Information Service has considered such an arrangement to be a form of tax optimisation. If this is confirmed in practice, then in the event of a tax audit the tax authority may demand that all income obtained from the company be taxed according to the progressive tax scale.
In practice, this means that a merely formal separation of contracts may not be enough. What is crucial is the actual nature of the activities, their scope, and whether the services provided within a sole proprietorship overlap with management functions.
This issue is returning for a reason
This is not a new problem. On the Outsourced.pl blog, we have already written about services provided to one’s own company and about the risks connected with the lump-sum regime. In 2022, we pointed to the changing approach of the tax authorities and refusals to issue tax rulings, and in 2025 we commented on the proposed regulations concerning a 17% lump-sum tax for services provided to a related company.
dr Piotr Sekulski, tax advisor
Although the change involving the introduction of a 17% lump-sum tax on services provided to one’s own company seems unfavourable, it could put an end to long-standing disputes concerning the tax treatment of management board members. The lack of this type of regulation means that entrepreneurs must remain cautious both with regard to settlements with their own company and to the choice of the lump-sum tax rate. It should be noted that the popular 8.5% rate is often challenged.
This clearly shows that the problem concerns not only the tax rate itself, but the entire structure of the cooperation model and the actual scope of duties.
If your situation involves a shareholder, manager or management board member providing additional services to their own company, it is worth analysing not only the choice of tax regime, but also the cooperation model itself, the scope of activities and the documentation. In these cases, the details really matter.
