PSI and R&D Relief – What’s Next After Pillar 2?
Since 2025, Poland has been applying new rules on the global minimum tax (Pillar 2). These regulations have a major impact on two of the most important tax incentives: the corporate/individual income tax exemption under the Polish Investment Zone (PSI) and the R&D tax relief.
How Pillar 2 Affects Tax Incentives
For the largest taxpayers, Pillar 2 may effectively eliminate the benefits of these incentives, reducing their attractiveness as tools to encourage investment and innovation.
Discussions on PSI and R&D Relief Reforms
Talks on amending the PSI legislation began as early as autumn 2024, aimed at ensuring that investment zones remain competitive. In spring 2025, the focus shifted to R&D relief, with announcements that draft amendments could be published around May–June 2025. The updated rules are expected to take effect from 1 January 2026.
No Drafts Published Yet
So far, however, no legislative drafts have been published regarding PSI or R&D relief. As a result, businesses remain uncertain about how these tax incentives will operate from next year.
Awaiting Ministry Decisions
The business community is waiting for concrete proposals from the Ministries, with the expectation that they will be released in time for taxpayers to prepare for the upcoming changes.
If you would like to understand how the changes to PSI and R&D relief may impact your company, get in touch with our expert.