Poland’s government has published the draft bill for the implementation of the pillar two global minimum tax in Poland under the EU Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022).
Previously, the Polish government announced that it introduced a draft legislation for implementing the pillar two global minimum tax in the country. The draft bill includes the introduction of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure 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.
The legislation also introduces the new ‘top-up tax opinion’ issued by the National Revenue Service. A top-up tax opinion application would incur fees between PLN 25,000 and PLN 75,000. The legislation is anticipated to take effect on 1 January 2025. However, some provisions of the bill may be enforced voluntarily starting from 1 January 2024.
