1. Investment vehicle
  2. 1. Form
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
    4. FIIS (Fonds d’investissement immobiliers spécialisés)
  3. 2. Tax Treatment
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  4. 3. Transfer Tax
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  5. 4. Listable
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  6. 5. Open- or closed-ended
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  7. 6. Regulatory Supervision
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  8. 7. Investor Restrictions
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  9. 8. Pros
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  10. 9. Cons
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund
  11. 10. Best Used For
    1. Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
    2. Alternative investment company ("ASI")
    3. Closed-ended investment fund

Updated on January 2026

Investment vehicle

  • Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds
  • Alternative investment company (“ASI”)
  • Closed-ended investment fund

1. Form

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Contractual, the fund itself is managed by an external licensed managing company (TFI)

Alternative investment company ("ASI")

  • Joint stock company / LLC / EU company / limited partnership / limited joint stock partnership

Closed-ended investment fund

  • Contractual, the fund itself is managed by an external licensed managing company (TFI)

FIIS (Fonds d’investissement immobiliers spécialisés)

  • Investment undertaking with fixed capital (SICAF)

2. Tax Treatment

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Opaque
  • Partial exemption depending on the type of income (generally, investments into tax transparent entities are subject to income tax)
  • Tax at investor level

Alternative investment company ("ASI")

  • Exemption for income from exit (disposal of shares, parent-subsidiary type generally applicable in cases when the fund holds more than 5% of shares in the portfolio company)
  • For other types of income, general taxation applies
  • Tax at investor level

Closed-ended investment fund

  • Opaque
  • Partial exemption depending on the type of income (generally, investments into tax transparent entities are subject to income tax)
  • Tax at investor level

3. Transfer Tax

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • 1% on non-tangible assets (e.g. shares in a Polish SPV) and 2% on tangible (e.g. RE located in Poland)

Alternative investment company ("ASI")

  • 1% on non-tangible assets (e.g. shares in a Polish SPV) and 2% on tangible (e.g. RE located in Poland) 

Closed-ended investment fund

  • 1% on non-tangible assets (e.g. shares in a Polish SPV) and 2% on tangible (e.g. RE located in Poland)

4. Listable

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • No

Alternative investment company ("ASI")

  • Yes, to the extent that they issue shares (i.e. in case of joins stock company, SE and limited joint stock partnership)

Closed-ended investment fund

  • Yes

5. Open- or closed-ended

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Open- or closed-ended

Alternative investment company ("ASI")

  • Open- or closed-ended

Closed-ended investment fund

  • Closed-ended

6. Regulatory Supervision

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Regulated by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego)

Alternative investment company ("ASI")

  • Regulated by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego), although, depending on the fund, the scope of supervision may be very limited

Closed-ended investment fund

  • Regulated by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego)

7. Investor Restrictions

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Yes, depending on the structure, limited to legal persons, partnerships, or individuals investing the PLN equivalent of EUR 40,000 minimum

Alternative investment company ("ASI")

  • Yes, to professional investors, distribution among retail investors is possible only with regards to ASI which obtained the authorization referred to in Article 5(1) of Regulation (EU) 2015/760

Closed-ended investment fund

  • Yes, limited to legal persons, partnerships, or individuals investing the PLN equivalent of EUR 40,000 minimum

8. Pros

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • No income tax at the fund level unless investments are made into tax transparent structures

Alternative investment company ("ASI")

  • Income tax exemption for disposal of portfolio shares

Closed-ended investment fund

  • No income tax at the fund level unless investments are made into tax transparent structures

9. Cons

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Limitation of possible investors

Alternative investment company ("ASI")

  • Limitation of possible investors

Closed-ended investment fund

  • Limitation of possible investors

10. Best Used For

Specialised open-ended investment fund applying investment restrictions of closed-ended investment funds

  • Specific types of investors preferring highly regulated entities

Alternative investment company ("ASI")

  • All strategies

Closed-ended investment fund

  • All strategies