Poland

During 2025 and in the beginning of 2026, there were little changes in regard to new corporate taxation. The changes mostly covered the amending of existing or implementation of already proposed regulations (e.g. National e-Invoice System, Pillar 2 regulations, CIT SAF-T file).

Changes in corporate income tax (CIT)

Legislative amendment effective from 2026 introduced permanently higher corporate income tax rates for banking sector entities: 23% for domestic and foreign banks, 21% for cooperative banks and credit unions, and 11% for small banking taxpayers.

Banks within tax capital groups are taxed at 23% proportionally to their share of group taxable income. Temporary higher CIT rates will apply in the first two years: 30% / 27% / 17% for 2026 and 26% / 23% / 13% for 2027. Special rules cover transitional periods for taxpayers with non-calendar fiscal years.  

The amendment also aligns with changes to the tax on financial institutions. For banks and branches of credit institutions, the standard monthly rate is reduced to 0.0293% of the tax base (down from 0.0366%), with a transitional rate of 0.0329% set for 2027. The rates for other financial institutions remain unchanged. 

The following significant amendments were introduced that impact CIT:

• The local minimum income tax regime applies for the first time since 2024, targeting taxpayers reporting operating losses or low profitability (income not exceeding  < 2% of the value of revenues).
• Poland’s implementation of the Pillart Two Directive has been effective since January 1, 2025. However, transitional provisions provide for the optional possibility of applying the provisions of this act retroactively, from 1 January 2024, based on the choice made. Multinational groups must prepare for full GloBE Information Return submission, application of transitional safe harbors and alignment with OECD Administrative Guidance.
• On 1 January 2025, the regulations regarding the so-called SAF_CIT structures (JPK_CIT in Polish) came into force. These regulations impose on taxpayers the obligation to keep accounting books in electronic form and to send them to the relevant head of the tax office after the end of the tax year. Taxpayers subject to this obligation must send two new logical SAF structures, which reflect the CIT calculation (JPK_KR_PD) and the fixed assets register prepared for CIT purposes. The obligation to submit JPK_CIT for CIT taxpayers with revenue exceeding EUR 50 million and tax capital groups starts from tax years beginning after 1 January 2025. However, the obligation to submit JPK_ST_KR for this group was postponed by one year and applies from 1 January 2026.
• Taxpayers required to submit SAF_CIT structures for the first time for the tax/financial year starting after 31 December 2024, by the deadline for filing a CIT return. However the Ministry of Finance has proposed permanently extending the JPK_CIT filing deadline to the end of the seventh month after the end of the tax year, meaning that the first reporting date under the new rules would fall on 31 July 2026.

• The amendment to the Commercial Companies Code entered into force on 15 September 2023 and introduced the following changes in restructuring activities, which also have effects in terms of CIT and tax ordinance:
  • A new method of division as an alternative to contribution-in-kind of a going concern while maintaining tax succession (i.e. division by separation). Such a division is tax neutral provided that the assets taken over and the assets remaining in the company constitute going concerns.
  • Simplified procedure for a zero-emission merger (i.e. without increasing the share capital [if the same partner/partners hold, directly or indirectly, all shares in the merging companies]).
  • Regulation on cross-border reorganisations (division, merger, transformation), including clarification of the provisions on tax succession and obligation to obtain the opinion of the Head of the National Tax Administration on the existence of a justified suspicion of tax avoidance or abuse of law, and confirmation that the company's financial obligations towards the authorities are satisfied or secured.

Changes in value-added tax (VAT)

The main areas of changes in the Polish VAT system for 2025 and subsequent years will be related to digitalisation of reporting obligations (i.e. mandatory e-invoicing system). The reform aims to standardize invoice data, enhance transaction transparency and support real-time analytics conducted by the tax administration. 

Other planned changes are intended to introduce simplifications, tighten the tax system, and adapt Polish VAT law to the judgments of the Court of Justice of the European Union (CJEU). However, there is only a draft of the act – currently in the phase of governmental consultations. 

In recent years, the majority of amendments (apart from digitalisation such as introduction of Central Electronic System of Payment Information) has focused on simplifications for taxpayers (in particular, implementation of three SLIM VAT legislative packages or introduction of VAT groups).

National e-Invoicing System 

As of 2022, the National e-Invoice System (the so-called KSeF) was launched, which enables issuance of and access to structured invoices. KSeF becomes mandatory according to the final phase implementation timetable: 

• 1 February 2026 (for taxpayers whose turnover exceeds PLN 200 million in 2024 - already in force - or 
• 1 April 2026 (for other taxpayers). 

At the same time the smallest taxpayers, whose total sales value (including tax) documented by invoices issued in a given month is less than or equal to PLN 10,000, can issue invoices in electronic or paper form until the end of 2026. This means they will be subject to the obligation of issuing structured invoices via KSeF from January 1, 2027.

Mandatory e-invoicing applies (in principle) to all transactions that have been so far documented with invoices (including domestic supplies of goods and services made between entrepreneurs [B2B] and public authorities [B2G]).

The B2C transactions can be documented on a voluntary basis.  

At the same time, the obligation to issue structured invoices is completely excluded in relation to transactions indicated in the regulation, such as highway tickets, transportation of passengers, orand certain services exempt from VAT (i.e. insurance and financial services).

On the other hand, the National e-Invoice System is optional for other foreign taxpayers who do not have a seat or a fixed establishment for VAT purposes in the territory of Poland.

The structured invoices and National e-Invoice System are discussed in more detail in the Other taxes section.

VAT in the Digital Age (ViDA) package (EU level)

The VAT in the Digital Age (ViDA) was adopted on March 11, 2025, after further consultation with the European Parliament, and its implementation will occur in stages until January 2035.

The main pillars of ViDA concern:

• Digital Reporting Requirements (DRR) and mandatory e-invoicing for B2B transactions within the European Union: The implementation date is generally 1 July 2030, with the EU e-invoicing standard applying to both intra-community and domestic transactions from 2035.
• Platform Economy: New rules may optionally be applied from 1 July 2028, with the obligation to implement them by 1 January 2030.
• Introduction of a single VAT registration: From 1 July 2028.

VAT exemption for small taxpayers

Taxpayers whose turnover did not exceed the specific threshold in the previous fiscal year (excluding VAT) are exempt from VAT. Starting January 1, 2026, this threshold is increased from 200,000 PLN to 240,000 PLN in annual turnover. This allows more micro-entrepreneurs to avoid VAT registration in Poland and reducing administrative burdens. The change applies to businesses with registered offices in Poland or other EU Member States (however, in the latter case additional requirements should be also met).

Central Electronic System of Payment information

As of 1 January 2024, payment service providers are required to keep electronic records of payment data for cross-border payments and to exchange these records with a newly established central EU-database, i.e. Central Electronic System of Payment information (the so-called CESOP). The purpose of the reporting obligation is to combat VAT fraud.

Under this reporting requirements, domestic banks, foreign bank branches, credit institutions, payment institutions, and credit unions must maintain, store, and report on cross-border payments to the Head of National Revenue Administration, when the payment service provider makes more than 25 such payments to the same payee per quarter.

Payment service providers must keep electronic records of cross-border payments for a period of three calendar years from the tax year the payment was made.

Other changes to the tax system

Mandatory Electronic delivery from 1 January 2026

• Following a prior implementation period, electronic delivery (e‑Delivery) becomes the primary channel for official correspondence from public authorities, and compulsory i.a. for all entities registered in the National Court Register (KRS) as of 1 January 2026. This new system replaces the previously permitted use of ePUAP, establishing e‑Delivery as the default method for official correspondence. In addition, the e‑Tax Office operates simultaneously and is preferred by tax authorities in some cases, but using it for official electronic correspondence requires the taxpayer’s explicit consent.

Customs duties

• A significant legislative update in Polish law came into force in 2025, targeting customs transactions. This amendment aims to align with EU law, enhance the enforcement of sanctions due to the conflict in Ukraine, and address loopholes that allow sanction circumvention. Notable changes include a requirement for evidence confirming goods are not for use in Russia or Belarus, and proof of customs clearance within 45 days post-EU departure. The customs and tax authorities has been given expanded powers to enforce these regulations, including the seizure of non-compliant goods.
• Additionally, businesses should note that on July 19, 2025 AIS/IMPORT PLUS system was implemented. This system replaced AIS/IMPORT, although no data migration completed , requiring the completion of current operations in the existing system.
• The European Union has intensified efforts to protect its internal market, evident from increased anti-dumping duties on imports from countries like China. Recent measures include definitive anti-dumping duties on various goods from China, Egypt, and the United States.
• As a member of the EU, Poland is indirectly influenced by the changing customs policies set by the United States that impact the EU. However, up until the beginning of 2026, there have been no specific customs duties imposed on imports from Poland. 

Property tax

As of 1 January 2025, businesses in Poland are affected by significant changes in property tax regulations. Key amendments redefine terms such as building, structure, construction facility, construction work, and permanent land attachment, now included in the Local Taxes and Fees Act, making it the primary source for RET terminology. Previously, deciding if an asset was subject to RET meant consulting the Construction Law. This may cause some properties to be categorised differently, potentially impacting tax liabilities.

Implementation of DAC7 to Polish law

Since 1 July 2024, digital platform operators in Poland have been subject to the of the DAC7 Directive to domestic law, which introduced harmonized EU obligations aimed at increasing transparency and preventing tax fraud. These operators, who facilitate transactions for sellers, must report seller data and adhere to due diligence procedures concerning sellers' status and information reliability. They are required to report activities such as real estate provision, personal services, goods sales, and transport rentals to the Head of the National Revenue Administration. 

The first reporting obligation was competed on 31 January 2025, covering 2023 and 2024. Subsequent reports should be submitted annually.

The requirement to publish tax strategy revoked

The obligation to prepare and publish information on the execution of the tax strategy, which applied to taxpayers with revenues exceeding 50 million euro in a tax year and to tax capital groups, was repealed as of 7 August 2025.