Poland’s Minister of Finance, Andrzej Domański, met with entrepreneurs and tax advisors to discuss proposals to adjust the research and development (R&D) tax relief to the GloBE system on 21 February 2025.

This announcement was made by Poland’s Minister of Finance on 28 February 2025.

The R&D tax relief provides special deduction rules for expenses related to conducting research and development activities, regulated under Article 18d of the Corporate Income Tax (CIT) Act and Article 26e of the Personal Income Tax (PIT) Act.

The discussion showed that this issue is important for taxpayers. The Ministry of Finance announced that the dialogue will continue to understand the expectations of stakeholders regarding the final solutions.

Three potential changes were discussed:

  1. Offering cash refunds for unused R&D tax relief deducted from the tax base.
  2. Offering cash refunds for unused R&D tax relief deducted from the tax (R&D Tax Credit).
  3. Dividing the current R&D relief into two components: one for salary costs, treated outside of CIT tax (based on the mechanism for innovative employees), and one for material costs, handled within the CIT relief.

Minister Domański stated that the Ministry aims to find a solution to maintain Poland’s international competitiveness and investment attractiveness.

Ministry representatives emphasised that these proposals are only a starting point for further discussion and that they are open to other suggestions. Key points from the meeting included:

  • Ensuring the proposed changes are neutral for both businesses (including those affected by equalisation taxes and other R&D relief beneficiaries) and the state budget. There was an understanding of the need to balance these objectives and the importance of keeping the R&D relief in the tax system to preserve Poland’s economic competitiveness.
  • Ensuring the compatibility of potential solutions with the requirements of the BEPS 2.0 project.
  • The need to implement the changes by January 1, 2026, with consideration for applying them to the current year as well.

Earlier, the Ministry of Finance announced that it will hold consultations on the direction of modifications to the research and development (R&D) tax relief in the context of the Pillar Two GloBE Rules on 21 February 2025.

Registrations for participation should be submitted by 19 February 2025.