Poland has enacted legislation implementing two EU tax directives — DAC8 and DAC9 — bringing new crypto-asset reporting obligations and centralised Pillar Two filing rules into domestic law, with the Act published in the Official Gazette on 17 March 2026. 

RF Report

Poland has published the Act of 13 February 2026 amending the Act on the Exchange of Tax Information with Other Countries and certain related legislation in the Official Gazette on 17 March 2026, implementing the Council Directive (EU) 2023/2226 of 17 October 2023 (DAC8) and Council Directive (EU) 2025/872 of 14 April 2025 (DAC9).

DAC8 introduces mandatory reporting and the automatic exchange of information on crypto-asset transactions to strengthen the fight against tax evasion and fraud. This directive introduces new reporting and due diligence obligations for crypto-asset service providers.

DAC8 aims to increase transparency regarding crypto asset ownership, which will help combat tax avoidance and evasion more effectively. It also facilitates enhanced information exchange on cross-border rulings for high-net-worth individuals and sets penalties and compliance measures for reporting obligations. DAC8 obligations generally take effect in 2026, with the first reporting due in 2027.

DAC9 establishes a legal framework for the automatic exchange of information on equalisation taxation, enabling the centralised filing of equalisation tax returns. The new rules allow ultimate parent entities or designated filing entities of an MNE group to file the top-up tax information return under Directive (EU) 2022/2523. This removes the need for other constituent entities in different EU Member States to file separately.

DAC9 also provides filing rules and a standard template for the return. As Poland implemented the Pillar Two GMT Directive late, the rules have been effective from 1 January 2025, with transitional provisions allowing application to tax years starting after 31 December 2023, consistent with the Directive.

Earlier, Poland’s Ministry of Finance announced, on 11 March 2026, that the Act on the Exchange of Tax Information with Other Countries and Certain Other Acts has been signed into law, implementing the Council Directive (EU) 2023/2226 (DAC8) and Council Directive (EU) 2025/872 (DAC9).