Poland's Minister of Finance and Economy published a notice on 15 June 2026 identifying foreign jurisdictions that have implemented a qualified income inclusion rule, a qualified domestic minimum top-up tax, or meet safe harbour requirements to align with global tax standards.
Poland has issued a notice identifying jurisdictions, other than Poland, that have introduced a qualified income inclusion rule (QIIR) or a qualified domestic minimum top-up tax (QDMTT), or that satisfy the QDMTT safe harbour conditions. The notice, issued by the Minister of Finance and Economy on 5 June 2026, was gazetted on 15 June 2026.
The notice identifies various foreign jurisdictions that have implemented a qualified income inclusion rule or a qualified domestic top-up tax to align with global standards. Additionally, the text specifies which regions meet the criteria for safe harbours concerning these compensatory taxes. Organised into comprehensive lists, the source includes effective dates for these tax measures across numerous global territories. This administrative act serves as a formal guide for multinational corporate groups to determine their tax obligations under the Polish Equalisation Tax Act.
Below are the jurisdictions categorised by the type of regulation implemented and the effective dates for tax years beginning on or after the specified dates.
Jurisdictions that implemented the Qualified Income Inclusion Rule (IIR)
The following 44 jurisdictions have implemented the IIR:
- Australia: 1 January 2024
- Austria: 31 December 2023
- Belgium: 31 December 2023
- Bulgaria: 31 December 2023
- Canada: 31 December 2023
- Croatia: 31 December 2023
- Cyprus: 31 December 2023
- Czech Republic: 31 December 2023
- Denmark: 31 December 2023
- Finland: 31 December 2023
- France: 31 December 2023
- Germany: 31 December 2023
- Gibraltar: 1 January 2025
- Greece: 31 December 2023
- Guernsey: 1 January 2025
- Hong Kong: 1 January 2025
- Hungary: 31 December 2023
- Indonesia: 1 January 2025
- Ireland: 31 December 2023
- Isle of Man: 1 January 2025
- Italy: 31 December 2023
- Japan: 1 April 2024
- Jersey: 1 January 2025
- Korea: 1 January 2024
- Liechtenstein: 1 January 2024
- Luxembourg: 31 December 2023
- Malaysia: 1 January 2025
- Netherlands: 31 December 2023
- New Zealand: 1 January 2025
- North Macedonia: 1 January 2024
- Norway: 1 January 2024
- Portugal: 1 January 2024
- Qatar: 1 January 2025
- Romania: 31 December 2023
- Singapore: 1 January 2025
- Slovenia: 31 December 2023
- South Africa: 1 January 2024
- Spain: 31 December 2023
- Sweden: 31 December 2023
- Switzerland: 1 January 2025
- Thailand: 1 January 2025
- Turkey: 1 January 2024
- United Kingdom: 31 December 2023
- Vietnam: 1 January 2024
Jurisdictions that implemented a Qualified Domestic Minimum Top-up Tax (QDMTT)
The following 49 jurisdictions have implemented a QDMTT (and these same 49 jurisdictions also meet Safe Harbour requirements for the QDMTT):
- Australia: 1 January 2024
- Austria: 31 December 2023
- Bahamas: 1 January 2024
- Bahrain: 1 January 2025
- Barbados: 1 January 2024
- Belgium: 31 December 2023
- Brazil: 1 January 2025
- Bulgaria: 31 December 2023
- Canada: 31 December 2023
- Croatia: 31 December 2023
- Czech Republic: 31 December 2023
- Denmark: 31 December 2023
- Finland: 31 December 2023
- France: 31 December 2023
- Germany: 31 December 2023
- Gibraltar: 1 January 2024
- Greece: 31 December 2023
- Guernsey: 1 January 2025
- Hong Kong: 1 January 2025
- Hungary: 31 December 2023
- Indonesia: 1 January 2025
- Ireland: 31 December 2023
- Isle of Man: 1 January 2025
- Italy: 31 December 2023
- Japan: 1 April 2026
- Kenya: 1 January 2025
- Kuwait: 1 January 2025
- Liechtenstein: 1 January 2024
- Luxembourg: 31 December 2023
- Malaysia: 1 January 2025
- Netherlands: 31 December 2023
- North Macedonia: 1 January 2024
- Norway: 1 January 2024
- Oman: 1 January 2025
- Portugal: 1 January 2024
- Qatar: 1 January 2025
- Romania: 31 December 2023
- Singapore: 1 January 2025
- Slovak Republic: 31 December 2023
- Slovenia: 31 December 2023
- South Africa: 1 January 2024
- Spain: 31 December 2023
- Sweden: 31 December 2023
- Switzerland: 1 January 2024
- Thailand: 1 January 2025
- Turkey: 1 January 2024
- United Arab Emirates: 1 January 2025
- United Kingdom: 31 December 2023
- Vietnam: 1 January 2024
The effective dates generally span from 31 December 2023 to 1 January 2025, with the exception of Japan, where the QDMTT and related safe harbour provisions take effect on 1 April 2026.
