The Polish government announced that it has introduced a draft legislation for implementing the pillar two global minimum tax in Poland in accordance with the EU Minimum Tax Directive (Council Directive (EU) 2022/2523) of 14 December 2022. The proposed bill is in the advanced stage of implementation. It is expected to be approved by the Council of Ministers in the third quarter of 2024, possibly effective from 1 January 2025.
The Polish administration intends to introduce the Qualified Domestic Minimum Top-Up Tax (QDMTT) as per the rules agreed within the Inclusive Framework. In addition, the government also intends to adopt the Undertaxed Profit Rule (UTPR) and the Income Inclusion Rule (IIR). The draft legislation proposes a minimum corporate tax of 15% for large multinational (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years.
If the effective tax rate of entities within a group falls under 15% in a specific jurisdiction, the group is required to pay a top-up tax.
