Draft Amendments to Tax Acts
A draft of amendments to Polish tax acts has been published, including changes to the PIT and CIT regulations. This is a comprehensive package of measures aimed at further tightening the tax system.
The proposed amendments include, among others:
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tightening provisions to prevent the misuse of so-called “loyalty programs,”
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clarifying the rules for determining tax-deductible costs in the case of the disposal of shares in a company created through transformation, and introducing taxation of shareholders’ income derived from the liquidation of such transformed entities,
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changing the rules for calculating income resulting from the redemption or reduction in the value of shares,
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clarifying provisions related to the solidarity levy,
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extending the ban on depreciation in real estate companies to also cover properties classified in accounting records as investments,
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introducing an employment condition for applying the IP Box regime,
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regulating the tax consequences of the disposal of assets acquired by close relatives of an entrepreneur who transferred them to private assets after the end of an operating lease, if they had previously been used in business activity,
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clarifying the definition of a “small taxpayer” in the CIT Act and introducing definitions of “taxpayer” and “entity commencing business activity,”
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changes to the taxation of shifted income, minimum tax, and the so-called Estonian CIT.
The new provisions are scheduled to enter into force on 1 January 2026. The draft legislation is available here: https://legislacja.rcl.gov.pl/projekt/12402157/katalog/13156654#13156654
At Thedy&Partners, we are closely analysing the potential impact of these regulations on business operations. We invite you to reach out – these changes may also be significant for your company.