🇵🇱 🇪🇺 Tax6 Nov 2024
Poland enacts its 15% minimum tax law from 2025
Poland's Act of 6 November 2024 on top-up tax of constituent entities of international and domestic groups, signed on 15 November and published on 19 November 2024, took effect on 1 January 2025. It applies a domestic top-up tax, income inclusion rule and undertaxed profits rule to groups with revenue of at least EUR 750 million. Groups could elect, between 1 March and 30 May 2026, to apply it from 2024.
Poland implemented the EU Minimum Tax Directive (2022/2523) a year late, one of four member states that missed the 2024 deadline.
What changed
- The act applies from 1 January 2025 to groups with consolidated revenue of at least EUR 750 million in two of the four previous years.
- A domestic top-up tax, which takes priority, plus the income inclusion rule and undertaxed profits rule, bring the effective rate in each jurisdiction to at least 15%.
- Groups could elect, between 1 March and 30 May 2026, to apply the act to the tax year starting 1 January 2024. The election is irrevocable.
Who is affected
Polish entities of large groups and their tax teams.