🧾 Introduction
If you invest in ETFs (Exchange-Traded Funds) through platforms like Revolut, eToro, or Interactive Brokers, you are legally required to declare your capital gains and dividends in Poland using the PIT-38 form.
This article explains, in simple terms, how to:
- Calculate the profit or loss when selling ETFs,
- Declare dividend income received from those ETFs,
- Apply the correct NBP currency exchange rate,
- And calculate your 19% capital gains tax.
Even if your broker didn't provide a PIT-8C, you can still fill PIT-38 manually using your account history.
🧩 Understanding How ETFs Are Taxed in Poland
ETFs generate two types of taxable income:
- Capital Gains (zyski kapitałowe) – when you sell ETF units for more than you paid.
- Dividends (dywidendy) – periodic payments you receive from ETFs that hold dividend-paying stocks.
Both types are declared in PIT-38, but they are taxed separately:
- Capital gains go into Part C of PIT-38.
- Dividends and other passive income go into Part G.
🧮 Example: Selling an ETF and Receiving Dividends
Let's take a realistic case based on a European investor using a foreign broker.
| Date | Event | Amount (EUR) | Details |
|---|---|---|---|
| 1 March 2024 | Buy 10 ETF units @ €100 | €1,000 | €2 commission |
| 1 July 2024 | Dividend payment | €20 | 15% tax withheld abroad (€3) |
| 1 September 2024 | Sell 10 ETF units @ €110 | €1,100 | €2 commission |
We will go step by step through the full calculation.
🧩 Step 1: Calculate Capital Gain (Sale Profit)
When you sell ETF units, your income (przychód) is the total sale value, and your cost (koszt uzyskania przychodu) is what you originally paid, including commissions.
💰 Income
Sale = €1,100
NBP exchange rate from 30 August 2024 = 4.60 PLN/EUR
So, your income for PIT-38 is:
1,100 × 4.60 = 5,060 PLN
📉 Costs
| Date | Description | EUR | Rate | PLN |
|---|---|---|---|---|
| 29 Feb 2024 | Purchase (€1,000 + €2) | 1,002 | 4.40 | 4,409 |
| 30 Aug 2024 | Sale Commission | 2 | 4.60 | 9 |
Total Costs = 4,409 + 9 = 4,418 PLN
✅ Profit
Income − Costs = 5,060 − 4,418 = 642 PLN
💡 Tax
PIT-38 uses a flat 19% rate for capital gains.
642 × 0.19 = 122 PLN
This amount will appear in Part C of PIT-38.
💶 Step 2: Declare Dividend Income
Dividend payments are taxed separately.
In our case:
- Gross dividend = €20
- Withholding tax (15% in the US) = €3
NBP rate from the day before payment (28 June 2024) = 4.55 PLN/EUR
| Description | EUR | PLN |
|---|---|---|
| Gross dividend | €20 | 91 PLN |
| Foreign tax paid | €3 | 13.65 PLN |
| Polish tax (19%) | — | 17.29 PLN |
You can deduct the foreign tax paid but only up to 17.29 PLN.
Final Polish tax due:
17.29 − 13.65 = 3.64 PLN
So you'll pay 3.64 PLN to Poland.
🧾 Step 3: Fill the PIT-38 Form
Capital Gains (Part C):
| Field | Description | PLN |
|---|---|---|
| 22 | Income | 5,060 |
| 23 | Costs | 4,418 |
| 26 | Profit | 642 |
| 31 | Tax (19%) | 122 |
Dividends (Part G):
| Field | Description | PLN |
|---|---|---|
| 44 | Polish tax due (19%) | 17.29 |
| 46 | Foreign tax paid | 13.65 |
| 47 | Tax to pay in Poland | 3.64 |
💱 Step 4: Use the Correct Exchange Rate
When converting EUR → PLN:
- Always use the NBP average rate from the last working day before the transaction.
- You can find official rates at www.nbp.pl.
This rule applies separately for:
- Each purchase
- Each sale
- Each dividend payment
- Each fee
Keeping a clear spreadsheet helps ensure accuracy if the Urząd Skarbowy requests verification.
🧠 Step 5: Keep Documentation
Don't attach any documents to your PIT-38 filing, but keep:
- Broker statements showing buy/sell details
- Dividend summaries
- Screenshots or PDF printouts of NBP exchange rates
- Foreign tax confirmations (for dividend credits)
These serve as proof if the tax office requests clarification.
⚠️ Common Mistakes to Avoid
- ❌ Using today's exchange rate instead of the historical NBP rate.
- ❌ Forgetting to include commissions in your costs.
- ❌ Not reporting foreign dividends because they "already withheld tax." (You must still report them!)
- ❌ Mixing ETFs with other assets — report all capital gains in one PIT-38 form.
✅ Summary
| Type | PLN | Tax (19%) |
|---|---|---|
| Capital gain | 642 | 122 |
| Dividend | 91 | 3.64 |
| Total tax due | — | 125.64 PLN |
💡 Final Notes
- Always file PIT-38 by April 30th for the previous year.
- If you hold ETFs through multiple brokers, combine all your transactions into one PIT-38.
- Keep your documents for at least 5 years in case of audit.
By understanding these steps, you'll confidently complete your PIT-38 without relying on your broker's summaries.