Amendments to gift and inheritance tax approved by Sejm
During the last session, the Lower House of the Polish Parliament (Sejm) passed a statue amending the gift and inheritance tax regime, by reinstating the time limit to notify the authorities of the acquisition of property and/or property rights by the members of the donor’s/testator's immediate family. The amendment also covers the instances of acquisition through inheritance and/or specific legacy of the ownership of a natural person’s enterprise or a share therein (click here for more information (in Polish)).
The Sejm also adopted other tax changes, including an increase in the revenue threshold allowing for the use of the cash PIT scheme from PLN 1 million to PLN 2 million (click here for more information (in Polish)).
The acts now move to the Upper House of the Polish Parliament.
Furthermore, the Sejm assessed the Senate’s amendments to the act amending the Act on Foreigners and Certain other acts, which provides for changes in the procedure for applying for a temporary residence permit, a permanent residence permit and a long-term EU resident's residence permit. The statute now awaits the President’s signature.
Update to OECD Model Tax Convention
On 18 November 2025, the OECD Council approved the latest update to the OECD Model Tax Convention on Income and on Capital, used by both OECD Members and non-Members as a basis for negotiating, applying and interpreting bilateral tax treaties. The 2025 update reflects the latest developments in international taxation, including clarified and expanded guidance on the interpretation of treaty provisions and issues related to remote working. The aim of the changes is to increase legal certainty, consistency in treaty practice and more effective resolution of double taxation issues. These changes will be incorporated into the forthcoming revised condensed and full editions of the OECD Model, to be published in 2026.
The 2025 Update to the OECD Model Tax Convention
More changes to bill on Polish National Labor Inspectorate
The Ministry of Family, Labor and Social Policy presented the third revision of the bill that gives inspectors of the Polish National Labor Inspectorate the right to convert civil law contracts into employment contracts by means of an administrative decision. The bill brings, inter alia, the following amendments:
- limiting the retroactive period for which a decision can be issued to 3 years,
- the possibility of revoking the immediate enforceability of a decision by the Chief Labor Inspector or a court,
- introducing liability for damages for incorrect decisions made by inspectors.
The possibility for the National Labor Inspectorate to bring actions before the court to determine the existence of an employment relationship has also been restored. The bill can be accessed here.
European Parliament backs simplification changes in sustainability reporting and due diligence
On 13 November 2025, the European Parliament endorsed the Omnibus I package, under which only businesses employing on average over 1750 employees and with a net annual turnover of over €450 million would be required to carry out social and environmental reporting, while due diligence requirements would apply only to large corporations with more than 5,000 employees and a net annual turnover of over €1.5 billion. Moreover, the European Commission adopted a “quick‑fix” to the ESRS standards allowing some data to be omitted from reports in 2025–2026 as well, to reduce the administrative burden.
Sustainability reporting and due diligence: MEPs back simplification changes
Higher contribution limit for Individual Retirement Protection Accounts in 2026
According to the notice of 10 November 2025, in 2026 the annual limit for contributions to Individual Retirement Protection Accounts (IKZE) will be PLN 11,304.
For individuals conducting non-agricultural business activity, the limit will be higher, i.e., PLN 16,956.
The increase in limits results from the provisions of the Act on Individual Pension Accounts and IKZE, which make the maximum contribution amount dependent on the projected average remuneration in the national economy. For comparison, in 2025 the limits were PLN 10,407.60 and PLN 15,611.40, respectively.
Please note that payments to IKZE accounts (up to the amounts specified above) can be deducted from:
- income taxed according to the tax scale,
- income taxed at a flat rate (19%),
- income taxed with lump-sum tax on recorded revenue.
Last call to apply for contribution holiday in 2025
The deadline for submitting applications for ‘contribution holiday’ in 2025 is the end of November. The relief is available to sole traders and allows them not to pay social security contributions for one month.
Contribution holiday is available to micro-entrepreneurs who meet certain conditions, including a limit on the number of insured persons registered (maximum 10), not exceeding the revenue threshold of EUR 2 million in the last two years, no activity for a former employer in the current and previous year, and no use of contribution holiday in 2025.
Uzyskaj miesięczne zwolnienie z opłacania składek ZUS w ramach wakacji składkowych
SAC: Employer-funded personal accident insurance policy covering unnamed employees does not give rise to taxable income for employee
Last week, the Supreme Administrative Court issued a judgment in case no. II FSK 335/25, in which it held that, considering the Constitutional Tribunal’s ruling (case file K 7/13), covering employees under an employer-funded unnamed personal accident insurance policy does not give rise to employment income subject to personal income tax. The Court emphasized that entering into such an insurance policy is primarily in the employer’s interest, since in the event of a workplace accident, compensation is paid by the insurer, thereby eliminating or reducing the employer’s obligation to cover the loss. The employee has no possibility to opt out of the insurance or obtain it on individually negotiated terms and therefore cannot be considered to benefit from it voluntarily.
SAC: First occupancy is counted from moment property is handed over to purchaser
In its judgment of 18 November 2025, the Supreme Administrative Court held that, under Article 2(14) of the VAT Act, “first occupancy” means the moment the property is made available for use. The Court indicated that, in the case at hand, this moment could not be equated with the later conclusion of lease agreements. The units were constructed, handed over to the purchaser, entered into the fixed asset register, and could be depreciated. It is therefore the act of transferring the property to the purchaser that constitutes the moment of first occupancy.
SAC: Registered partnership is required to file CIT-15J information for every financial year
Last week, the Supreme Administrative Court ruled (in case no. II FSK 327/25) that submitting the CIT‑15J form within 14 days of registering a registered partnership does not release it from the obligation to file this information in subsequent financial years, even if no changes have occurred in the composition of the partners. A registered partnership must submit the CIT‑15J form before the beginning of each financial year to maintain tax transparency and avoid being subject to corporate income tax. This requirement will change only as of 1 January 2026, since, under the amendment of 25 June 2025, registered partnerships will no longer be required to file the CIT‑15J form if the information previously submitted remains valid.