Accounting obligations of a family foundation: what does accounting look like in practice, step by step?

Family foundation accounting means full books of account kept under the Accounting Act, supplemented by the records needed for CIT settlements. A family foundation cannot keep simplified accounting, even if it only manages assets. Below, we show what this accounting looks like in practice, which documents are needed and which mistakes to avoid.

Does a family foundation have to keep full accounting?

Yes. A family foundation is a legal person, and legal persons with their registered office in Poland apply the Accounting Act. This means an obligation to keep full books of account and to prepare annual financial statements. Keeping a revenue and expense ledger (książka przychodów i rozchodów) or using the lump-sum tax (ryczałt) is not an option here.

Under Article 4(1) of the Family Foundation Act, a foundation acquires legal personality upon entry in the register of family foundations. The register is kept by the Regional Court in Piotrków Trybunalski. From that moment, the foundation operates like any other entity applying the Accounting Act.

Full accounting applies regardless of the scale of activity. It concerns both a foundation that has one flat for rent and a foundation with a portfolio of a dozen or so companies. Only the number of events to be recorded differs, not the obligation itself.

Which regulations govern family foundation accounting?

Family foundation accounting is based on three acts. The Accounting Act sets out the rules for keeping books and for financial reporting. The Family Foundation Act regulates assets, the inventory of assets and beneficiaries, and the CIT Act sets out the rules of taxation.

The basic tax rule is that a family foundation benefits from the CIT exemption. However, the exemption has exceptions. That is why the books must make it possible to distinguish exempt revenue from events that give rise to tax.

What does family foundation accounting look like in practice?

In practice, family foundation accounting combines the ordinary recording of events with very detailed records of assets and benefits. The system must make it possible to reconstruct the history of each asset and each payment to a beneficiary. Without this, it is difficult to settle CIT correctly and to prepare the financial statements.

The starting point is the accounting policy. Under Article 10 of the Accounting Act, the head of the entity, which in a foundation means the management board, sets it out in writing and updates it. It covers, among other things, the company chart of accounts and the valuation rules. In a family foundation, it is worth preparing it before the first event is entered in the books. We help with this as part of our accounting policy preparation service.

Contribution of assets and opening of the books

The first event in the books is usually the contribution of assets by the founder. The founder contributes assets to cover the founding fund with a value specified in the statute, not lower than PLN 100,000 (Article 17 of the Family Foundation Act). This may be cash, real estate, shares or stock.

The books are opened as at the day the activity commences, i.e. the day of the first event with property or financial consequences. The Accounting Act allows 15 days from such an event for this. In a family foundation, it is worth establishing straight away how to recognise contributions from several founders, as this data will be needed throughout the foundation’s existence.

Ongoing events: rental, investments, interest, dividends

Ongoing accounting covers all events related to the foundation’s assets. For real estate, these include rent, utilities, outlays, depreciation and property tax. For investments, these include the purchase and sale of securities, dividends, interest and exchange differences.

The key is to assign each item of revenue to the correct category. Article 5 of the Family Foundation Act sets out a closed catalogue of business activities that a foundation may conduct. These include, among others:

• disposal of assets, if they were not acquired solely for the purpose of further disposal,
• rental, lease and making assets available for use,
• participation in companies and investment funds,
• trading in securities,
• granting loans to capital companies in which the foundation holds shares or stock, to partnerships in which it is a partner, and to beneficiaries,
• trading in foreign means of payment in order to make payments related to the foundation’s activity,
• certain non-industrial processing of agricultural products and forestry, solely in connection with an agricultural holding being run.

Activity outside this catalogue is taxed at the 25% CIT rate (Article 24r of the CIT Act). That is why the revenue analytics should show straight away which source every zloty comes from. Rental to the founder, a beneficiary or entities related to them requires separate analysis. Under Article 6(8) of the CIT Act, the exemption does not cover revenue from rental or lease if its subject is an enterprise, an organised part of an enterprise or assets used in the business activity of such a person or entity, where the statutory conditions are met. The mere fact of renting premises to the founder or a beneficiary does not automatically mean the loss of the exemption.

Benefits for beneficiaries and their records

A benefit is cash, items or rights transferred to a beneficiary or made available for their use in accordance with the statute and the list of beneficiaries (Article 2(2) of the Family Foundation Act). On a benefit, the foundation pays 15% CIT (Article 24q of the CIT Act). The same rate applies to assets transferred upon the dissolution of the foundation and to benefits in the form of so-called hidden profits, listed in Article 24q(1a), e.g. certain transactions with the founder, a beneficiary or related entities. The tax is paid by the 20th day of the month following the month in which the benefit was transferred or made available.

Example: the foundation pays a beneficiary PLN 100,000. We assume that the beneficiary belongs to the so-called group “0” in relation to the founder. The beneficiary receives PLN 100,000, and the foundation additionally recognises PLN 15,000 of CIT. The tax is borne by the foundation as the taxpayer, so the amount of the benefit is not reduced by it. If the beneficiary did not belong to the so-called group “0” in relation to the founder, the appropriate PIT would have to be withheld from the payment of this benefit to the beneficiary.

For each benefit, the books and documentation should show:

• the beneficiary and the basis for the benefit in the statute,
• the type of benefit (cash or non-cash),
• the value and the date of transfer or making available,
• the data needed for settlement on the beneficiary’s side.

Inventory of assets and the books of account

The inventory of assets is a separate document required by the Family Foundation Act. It includes, among other things, the person contributing the assets, the type and value of each asset according to its condition and prices at the time of contribution, and its tax value. The management board updates the inventory with each subsequent contribution.

The inventory of assets does not replace the books of account. The books show all events and the current value of assets according to accounting rules. The inventory documents who contributed what. Data from both sources should be capable of being linked, as it is needed, among other things, when settling benefits.

Which documents must a family foundation prepare and keep?

A family foundation needs four groups of documents: corporate, asset-related, accounting and tax. Every entry in the books must be based on an accounting document. In a foundation, documentation of benefits and contributions is particularly important, because tax settlements depend on it.

Documents are kept for the periods specified in Article 74 of the Accounting Act. Longer periods may result from tax regulations, e.g. from the running of the limitation period for tax liabilities.

Calendar of accounting and tax obligations of a family foundation

A family foundation’s obligations follow a monthly and an annual cycle. Each month, the books are closed and taxes on events from that month are settled. Once a year, the financial statements and the CIT-8FR return are prepared.

Where the financial year is the same as the calendar year, the calendar looks like this:

If the foundation conducts activity outside the scope of Article 5, it also files a CIT-8 return to that extent (Article 27(1da) of the CIT Act) together with the CIT/F information form. If it is a VAT taxpayer, VAT settlements and obligations related to the National e-Invoicing System (KSeF) also apply.

A family foundation is not exempt from JPK CIT. The Ministry of Finance confirms that Article 9(1d)(1) of the CIT Act excludes taxpayers exempt from CIT from this obligation, with the exception of family foundations. However, the obligation is being introduced in stages. A foundation that files a monthly JPK_V7M submits its books for years beginning after 31 December 2025. Other foundations do so for years beginning after 31 December 2026. We describe the schedule of the obligation in the article JPK_CIT in 2026: deadlines, JPK_KR_PD structure and new obligations (April 2026).

The most common mistakes in family foundation accounting

The most common mistakes result from treating a family foundation like an ordinary company or like a simple “portfolio” of assets. In both cases, the books do not show the data required by the regulations on foundations. This may result in errors in CIT and in the financial statements.

Typical mistakes include:

1. No separation of revenue sources. A single “revenue” account makes it impossible to show what falls within Article 5 and what is subject to 25% CIT.
2. Recording benefits as ordinary costs. A benefit is a transfer of assets to a beneficiary, not a business cost.
3. Reducing the benefit by the 15% CIT. The tax is borne by the foundation, not by the beneficiary.
4. Equating the inventory of assets with the books. The inventory documents contributions but does not replace the accounting records.
5. Transferring solutions from companies without analysis. Contributing assets to a foundation is not an in-kind contribution to a company.
6. No documentation of transactions with the founder and beneficiaries. Such transactions may have tax consequences, so they require full documentation.

Who can keep the books of a family foundation?

The books may be kept by the foundation itself or by an accounting firm. Article 11 of the Accounting Act allows the keeping of books to be entrusted to an entrepreneur who meets the statutory conditions. However, responsibility for the accounting remains with the foundation’s management board.

When choosing an accounting firm, it is worth checking whether it has experience in settlements specific to family foundations. This applies in particular to benefits, 15% CIT, the qualification of activity under Article 5 and cooperation during the audit. Equally important is cooperation between the accounting team and a tax adviser, because many accounting decisions have a direct impact on CIT.

FAQ

Can a family foundation keep simplified accounting?

No. A family foundation is a legal person, so it applies the Accounting Act and keeps full books of account. It cannot keep a tax revenue and expense ledger or use the lump-sum tax. This obligation does not depend on the size of the assets or the number of transactions. A foundation with one rented property keeps books under the same rules as a foundation with a large investment portfolio.

Does a family foundation pay CIT?

As a rule, a family foundation is exempt from CIT under Article 6(1)(25) of the CIT Act. However, the exemption has exceptions. The foundation pays 15% CIT on benefits for beneficiaries, on assets transferred upon the dissolution of the foundation and on so-called hidden profits. It also pays 25% CIT on business activity going beyond the scope of Article 5 of the Family Foundation Act.

Which CIT return does a family foundation file?

A family foundation files the CIT-8FR return by the end of the third month of the following year, electronically (Article 24s of the CIT Act). It pays the tax on benefits on an ongoing basis, by the 20th day of the month following the month in which the benefit was transferred. If it conducts activity outside the scope of Article 5 of the Family Foundation Act, it also files a CIT-8 return with the CIT/F information form to that extent.

How does the inventory of assets differ from the books of account?

The inventory of assets is a document under the Family Foundation Act. It shows who contributed the assets, what they were, what their value was at the time of contribution and what their tax value is. The books of account, on the other hand, cover all business events and the current value of assets. Both sources should be capable of being linked, but one does not replace the other.

Does a family foundation have to file JPK CIT?

Yes. The Ministry of Finance indicates that Article 9(1d)(1) of the CIT Act exempts taxpayers exempt from CIT from JPK CIT, with the exception of family foundations. The obligation is being introduced in stages: foundations filing a monthly JPK_V7M submit their books for years beginning after 31 December 2025, and the others for years beginning after 31 December 2026.

Can an accounting firm keep the books of a family foundation?

Yes. The Accounting Act allows the keeping of books to be entrusted to an accounting firm. However, the foundation’s management board remains responsible for the accounting, including the accounting policy and the financial statements. It is worth choosing a firm that knows the specifics of family foundations: benefits, 15% CIT, the qualification of activity under Article 5 and preparation for the audit.

How ALTO can help

We keep the books of family foundations from the first day of their activity. We help prepare the accounting policy and the chart of accounts, record founders’ contributions and settle benefits for beneficiaries. Our accounting team works with tax advisers, so the qualification of events takes account of the CIT consequences from the outset. Find out more about our support in setting up a family foundation.

Accounting for family foundations at ALTO is the responsibility of Katarzyna Pędzich, Accounting Senior Manager.

Sources

• Act of 26 January 2023 on Family Foundations (Ustawa z dnia 26 stycznia 2023 r. o fundacji rodzinnej), Journal of Laws 2023, item 326, as amended, Articles 2, 4, 5, 17, 72
• Accounting Act of 29 September 1994 (Ustawa z dnia 29 września 1994 r. o rachunkowości), Journal of Laws 2026, item 522, Articles 2, 10, 11, 52, 53, 69, 74
• Corporate Income Tax Act of 15 February 1992 (Ustawa z dnia 15 lutego 1992 r. o podatku dochodowym od osób prawnych), Journal of Laws 2026, item 554, Articles 6, 9, 24q, 24r, 24s, 27
• Ministry of Finance, JPK_PD questions and answers (Pytania i odpowiedzi JPK_PD): https://www.podatki.gov.pl/podatki-firmowe/jednolity-plik-kontrolny/jpk_pd/pytania-i-odpowiedzi-jpk_pd
• Regional Court in Piotrków Trybunalski, Register of Family Foundations (Rejestr Fundacji Rodzinnych): https://piotrkow-tryb.so.gov.pl/rejestr-fundacji-rodzinnych,m,mg,305