Poland’s Senate has passed legislation simplifying transfer pricing reporting for micro and small businesses while introducing stricter bank-account payment requirements for tax-deductible expenses from 1 January 2027 and clarifying information-exchange rules for transactions with foreign related entities.
Poland’s Senate (Upper house of Parliament) passed a legislation that reshapes how small businesses handle tax reporting and cash transactions.
The Act of 18 September 2026, transmitted as Senate Print No. 834 (Druk nr 834), amends both the Personal Income Tax (PIT) Act and the Corporate Income Tax (CIT) Act to reduce administrative burdens on micro and small enterprises while enforcing stricter controls on non-cash business payments and international tax transparency.
The changes affect businesses filing transfer pricing reports, managing tax-deductible expenses, and conducting transactions with foreign-related entities. Micro-entrepreneurs and small business owners will see immediate relief from certain reporting requirements, but all companies must adapt to new payment rules that take effect in January 2027.
The legislation enters force 14 days after official publication in the government gazette and phases in over the next year.
Transfer pricing reporting gets simpler
The Act of 18 September 2026 simplifies Poland’s annual Transfer Pricing Information (TPR) reporting process. Electronic authorisation to sign tax returns will now automatically cover TPR forms, removing the need for separate powers of attorney. Micro-enterprises and small businesses also benefit from exemptions from certain general financial and controlled-transaction disclosures.
The Ministry of Finance is expected to issue regulations by 30 June 2027 specifying the data that will continue to be required in TPR forms.
All business payments must use bank accounts
Starting 1 January 2027, the tax authorities will enforce stricter rules on business expense deductions. Article 22p (PIT) and Article 15d (CIT) now require that tax-deductible business expenses must be paid through a payment account.
Any payment made directly, without routing through a bank account, cannot be deducted as a business cost in the month the payment occurs.
This mandate applies to transactions governed by Article 19 of the Entrepreneurs’ Law. The previous exemptions under Article 14 and Article 22p (PIT) and Article 12 and Article 15d (CIT) no longer apply. However, invoices issued before 1 January 2027 remain subject to the former rules.
International tax transparency rules clarified
For transactions with foreign related entities, Article 23q point 4 (PIT) and Article 11e point 4 (CIT) now require an explicit legal basis for information exchange. Exemptions and special treatment apply only when a formal agreement exists to share tax information with the country where the related entity operates.
Implementation timeline
The TPR reporting changes take effect for tax years starting after 31 December 2025. Taxpayers whose tax year spans the transition (starting before 1 January 2026 and ending after 31 December 2025) follow the previous rules for that period.
The payment account requirement becomes mandatory on 1 January 2027 for all invoices dated from that date onward.
The Ministry of Finance has until 30 June 2027 to publish updated regulations for TPR submission requirements. Current executive decrees remain valid until these new regulations take effect.
Earlier, Poland’s Council of Ministers approved amendments to the Personal Income Tax Act and Corporate Income Tax Act on 21 July 2026 to simplify transfer pricing disclosure requirements and reduce penalties for incorrectly reported payments.
