JDG vs Sp. z o.o. vs Estonian CIT for STR: Comparison Table 2026
Sole proprietorship on 8.5% flat-rate vs Polish LLC on 9% CIT vs Estonian CIT 10%: tax, ZUS, accounting and breakeven for STR in 2026.
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JDG vs Sp. z o.o. vs Estonian CIT for STR: Comparison Table 2026
Sole proprietorship on ryczalt 8.5%/12.5%, sp. z o.o. on classic CIT 9% or Estonian CIT 0% on reinvestment: which form gives the highest net profit for an STR owner? Full comparison on real numbers across 5 revenue brackets in 2026.
Choosing the legal form for short-term rental is one of the most important decisions an STR investor makes. The difference between JDG (Polish sole proprietorship) and a company can reach PLN 50,000 per year net at the same revenue. In this article we compare the three most popular forms: JDG on ryczalt, sp. z o.o. on classic CIT 9% and sp. z o.o. on Estonian CIT, across five annual revenue brackets: PLN 100,000, 250,000, 500,000, 1,000,000 and 2,000,000.
Profile of the Three Forms
JDG on ryczalt (PIT-28)
- Rates: 8.5% up to PLN 100,000, 12.5% above (for short-term rental)
- No cost deduction
- Social ZUS: full entrepreneur contributions (~PLN 1,900-2,000/m = approx. PLN 23,000-24,000/yr in 2026)
- Health contribution on ryczalt: a flat amount by 3 revenue brackets (at PLN 60,000-300,000 about PLN 700-750/m, higher above PLN 300,000) - NOT 9% of income
- Bookkeeping: simple ryczalt revenue ledger
- Liability: unlimited, with personal assets
Sp. z o.o. on classic CIT 9%
- CIT rate: 9% (small taxpayers up to EUR 2M), 19% others
- Full cost deduction
- Owner ZUS: PLN 0 if no salary drawn
- Profit payout: dividend taxed 19% PIT (combined rate ~26%)
- Bookkeeping: full (PLN 4,000 to 9,600 per year)
- Liability: limited to capital contribution
Sp. z o.o. on Estonian CIT
- Rate: 0% on reinvestment, 10% (small) or 20% (others) on payout
- No tax-cost accounting (including the anyway-banned depreciation of residential premises)
- Owner ZUS: PLN 0 (if the company has at least 2 shareholders)
- Required: at least 3 people who are NOT shareholders (softer threshold for a new company and small taxpayer - no requirement in the first year)
- Bookkeeping: full ledger
- Decision: binding for 4 years
Comparison Table for 5 Revenue Brackets
Assumptions: operating costs 30% of revenue (cleaning, platform commissions, utilities, insurance), owner draws 100% of profit, for Estonian CIT we assume 50% reinvestment + 50% payout. NOTE: in the JDG ryczalt column the "ZUS" figure covers only the full social contributions of an entrepreneur in 2026 (about PLN 23,000/yr). On top of that comes the ryczalt health contribution (by 3 revenue brackets, about PLN 8,000-9,000/yr at PLN 60,000-300,000 of revenue), which for simplicity is not included in the table - the real JDG burden is higher by that amount.
| Revenue | JDG ryczalt | Sp. z o.o. CIT 9% | Sp. z o.o. Estonian CIT |
|---|---|---|---|
| PLN 100,000 | Tax 8,500 + ZUS 23,000 = 31,500, profit 68,500 (+ health approx. 8,000-9,000) | Tax 6,300 + dividend 19% of 63,700 = 18,403, profit 81,597 (less 9,600 books = 71,997) | Tax 3,150 + 6,370 PIT = 9,520, profit 80,480 (less 9,600 books = 70,880) |
| PLN 250,000 | Tax 27,250 + ZUS 23,000 = 50,250, profit 199,750 (+ health approx. 8,000-9,000) | Tax 15,750 + dividend 30,268 = 46,018, profit 203,982 (less 9,600 books = 194,382) | Tax 8,750 + PIT 17,675 = 26,425, profit 223,575 (less 9,600 books = 213,975) |
| PLN 500,000 | Tax 58,500 + ZUS 23,000 = 81,500, profit 418,500 (+ health by bracket) | Tax 31,500 + dividend 60,537 = 92,037, profit 407,963 (less 9,600 books = 398,363) | Tax 17,500 + PIT 35,350 = 52,850, profit 447,150 (less 9,600 books = 437,550) |
| PLN 1,000,000 | Tax 121,000 + ZUS 23,000 = 144,000, profit 856,000 (+ health by bracket) | Tax 63,000 + dividend 121,075 = 184,075, profit 815,925 (less 9,600 books = 806,325) | Tax 35,000 + PIT 70,700 = 105,700, profit 894,300 (less 9,600 books = 884,700) |
| PLN 2,000,000 | Tax 246,000 + ZUS 23,000 = 269,000, profit 1,731,000 (+ health by bracket) | Tax 126,000 + dividend 242,150 = 368,150, profit 1,631,850 (less 9,600 books = 1,622,250) | Tax 70,000 + PIT 141,400 = 211,400, profit 1,788,600 (less 9,600 books = 1,779,000) |
Conclusion: Winner per Revenue Bracket
| Revenue | Best form | Difference vs second |
|---|---|---|
| PLN 100,000 | JDG ryczalt | +PLN 3,303 vs CIT 9% |
| PLN 250,000 | Estonian CIT | +PLN 7,425 vs JDG |
| PLN 500,000 | Estonian CIT | +PLN 12,250 vs JDG |
| PLN 1,000,000 | Estonian CIT | +PLN 21,900 vs JDG |
| PLN 2,000,000 | Estonian CIT | +PLN 41,200 vs JDG |
Decision threshold: PLN 200,000 of annual revenue. Below it, JDG ryczalt is the simplest and cheapest. Above it, Estonian CIT starts to pay off if you can meet the 3-employee condition.
Other Criteria Beyond Net Profit
Personal asset protection
JDG: zero, you are liable with everything. Sp. z o.o.: full, limited to capital contribution.
Operational complexity
JDG: very simple, you can run it yourself. Sp. z o.o.: requires an accountant, 5 to 10 times more documents.
Setup time
JDG: 5 minutes online (CEIDG-1 form). Sp. z o.o.: usually 1 to 3 days via S24, 4 to 6 weeks at a notary.
Setup cost
JDG: PLN 0. Sp. z o.o.: PLN 5,000 capital + PLN 375 court fee minimum.
Selling the business
JDG: hard (asset sale + contract assignment). Sp. z o.o.: easy (share sale in a single deed).
Criminal liability
JDG: full. Sp. z o.o.: limited, mostly only as governing body (board), not shareholder.
Special Cases
Owner with full-time employment
If your employment pays at least the minimum wage (and employment is a separate insurance title from JDG), the business activity gives an overlap of titles: social ZUS from JDG is voluntary, so from the business you pay only the health contribution - and INDEFINITELY, as long as the employment at the minimum wage lasts. This genuinely lowers the cost of running JDG alongside a job. Such hosts often start with JDG and switch to a company at larger scale.
Retiree owner
A retiree running JDG does not pay ZUS (only health). This can shift the balance toward JDG even at higher revenue.
Foreign owner
A non-resident foreigner can run JDG only after obtaining a residence permit (apart from EU/EEA citizens). Sp. z o.o. is available immediately without that limit, which is why UK and US investors often pick a company straight away.
Hybrid Strategy: Several Forms in Parallel
Experienced STR investors with 10+ flats use a hybrid model:
- Best 2-3 flats in sp. z o.o. on Estonian CIT (reinvestment)
- The rest in JDG on ryczalt (simple settlement)
- Flats bought before 2020 often stay in private rental on ryczalt
This requires 2 to 3 sets of bookkeeping but delivers tax optimum.
Frequently Asked Questions
Can I switch from JDG to a company mid-year?
Yes, but it requires a formal process: incorporate the company, contribute the JDG enterprise as in-kind contribution, update platform contracts, close JDG. Mid-year you file two PITs: PIT-28 from JDG until transfer date, CIT-8 from the company after transfer.
What if I have 1 flat and PLN 80,000 revenue, does a company make sense?
No. For 1 flat and PLN 80,000 revenue, JDG on ryczalt is clearly the best. A company generates servicing costs (PLN 9,600/year bookkeeping) that eat the tax savings. Start with JDG, move to a company at PLN 250,000 of annual revenue.
Is Estonian CIT the same as "no tax"?
No, it is "tax deferral". All reinvested profit sits in the company and is NOT taxed as long as it stays there. But on payout (dividend, sale of company, liquidation) CIT 10% (small) or 20% (others) is collected. The shareholder also pays 19% PIT on the dividend, but deducts from it 90% (small taxpayers) or 70% (others) of the CIT paid by the company - so the effective combined burden is materially lower than the sum of both taxes.
Can I be on ryczalt but still keep a revenue and cost ledger?
No. Ryczalt is a simplified form where you only keep a ryczalt revenue ledger. No costs, no depreciation, no annual P&L. If you want to deduct costs you must choose general rules (PIT-36) or a company (CIT).
What about VAT in STR?
Regardless of legal form, accommodation services are subject to VAT 8%. You use the subjective exemption up to PLN 240,000 annual turnover (the limit in force from 1 January 2026; previously PLN 200,000), above which the obligation to register as an active VAT payer arises. Companies more often register as active VAT payers by choice (input VAT deduction).
Can Estonian CIT be combined with flat depreciation?
No - and in practice it does not matter. Since 1 January 2023 there is a complete ban on tax depreciation of residential premises and buildings, in both PIT and classic CIT. So the flat's value does not reduce the tax base in any of these regimes. The "classic CIT with property depreciation" argument no longer applies - you cannot depreciate a residential flat for tax purposes regardless of the chosen form.
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