On 28 June 2022, the Polish government announced a draft law to proposing significant changes to the Polish Corporate Income Tax Act. The proposed changes impact the following areas;
- The effective date of the new “minimum tax” will be postponed to 1 January 2023, along with an increase in the profit level indicator from 1% to 2%.
- Abolish the so-called “hidden dividend” regulations.
- Modification to Controlled Foreign Corporations (CFCs) regulations, containing provisions to eliminate double or multiple taxation of CFCs making dividend payments within holding structures.
- Amendments to relax withholding tax requirements for payments exceeding PLN 2 million per year, including a waiver of requirements related to interest and discounts on government securities.
- Expanded scope of corporate income tax exemption for interest or discount and capital gains earned by non-residents investing in Polish securities issued by the Treasury.
- Changes in the “Polish Holding Company Regime”, which include increasing the tax exemption for dividends received from qualified subsidiaries to 100% from 95%.
The proposed amendments to the draft law will generally come into force on 1 January 2023.
