The deadline for submitting comments is 26 September 2025.
Poland’s Ministry of Finance has initiated a public consultation on 16 September 2025 regarding the draft amendments to the Corporate Income Tax (CIT) framework.
The proposed corporate tax measures are as follows:
Distribution tax expansion
- Under the draft legislation, the definition of hidden profits subject to distribution tax will be broadened. Fees and payments generated from lease, tenancy, or similar agreements will now be included in the catalogue of hidden profits.
- In addition, the Ministry has proposed a clear definition for non-business-related expenses covering costs incurred for purposes other than generating revenue or maintaining a revenue source.
- The reduced distribution tax rate will no longer apply to companies formed through corporate transformation, unless they meet the criteria of small taxpayers.
Flat rate tax on related-party services
To tackle widespread tax optimisation practices, the proposed rules introduce a 17% flat rate tax on services provided to related entities.
Revisions to depreciation rules
- Taxpayers generating income exempt from taxation will no longer be permitted to retroactively adjust depreciation rates after filing their annual return
- Real estate companies will be prohibited from applying tax depreciation to long-term investment properties.
The proposed measures are expected to come into effect on 1 January 2026.
Interested parties are requested to submit comments by 26 September 2025.
