Tax changes for 2027 passed by Sejm

Tax changes for 2027 passed by Sejm

On 22 October 2026, the Sejm passed a package of legislation amending, among other things, PIT, CIT, lump-sum income tax, VAT and excise duty regulations. The amendments provide in particular for the introduction of three PIT brackets, with rates of 12%, 24% and 32%, restrictions on access to lump-sum income tax, an increase in the CIT rate to 22% for taxpayers with revenue exceeding the equivalent of EUR 50 million and for tax groups, and an increase in the solidarity levy from 4% to 5% (druk nr 3147). The package also includes changes concerning Estonian CIT druk nr 3137), depreciation, family foundations (druk nr 3148) and transactions with related parties. The relief for robotisation has also been extended until 2036, while the expansion relief and Internet relief are to be abolished (druk nr 3149). At the same time, the tax preference for honorary blood donors is to be increased. The Sejm has also passed an increase in excise duty on alcohol (druk nr 3136) and the application of the 23% VAT rate to selected non-alcoholic and energy drinks (druk nr 3135). The Act now moves to the Senate with most of the changes expected to enter into force on 1 January 2027.

Last week, the Council of Ministers approved a bill amending the VAT Act, which provides for the application of financial penalties for errors relating to the National e-Invoicing System (KSeF) to be deferred until 31 December 2027. The bill also provides for the VAT reverse-charge mechanism for gas supplied through the gas system, electricity and services involving the transfer of greenhouse gas emission allowances to be extended until 30 June 2030. The bill has already been submitted to the Sejm, and the new provisions are expected to enter into force on 31 December 2026.

On 19 October 2026, an opinion of the Director of the National Revenue Information Service (ref. 0111-KDGB.480.6.2026.2.TŁ) concerning qualifying financial statements for top-up tax purposes was published. The Director of the National Revenue Information Service held that the standalone financial statements of Polish group entities, prepared in accordance with IAS/IFRS or the Polish Accounting Act and Polish Accounting Standards, may constitute qualifying financial statements for the purposes of the transitional CbCR safe harbour, provided that they are based on an acceptable accounting standard and contain reliable information.

In a judgment of 21 October 2026 (case file I FSK 2247/23), the Supreme Administrative Court held that the option to waive the VAT exemption provided for in Article 43(22) of the VAT Act applies exclusively to services with the place of supply being in Poland. A taxpayer providing financial services to foreign entities which, by virtue of their place of supply, are not subject to VAT in Poland cannot validly opt to tax those services. Consequently, the taxpayer also cannot treat those services as hypothetically taxable in Poland for the purposes of deducting input VAT under Article 86(8)(1) of the VAT Act.

In the latest International Tax Competitiveness Index compiled by the Tax Foundation, Poland ranked 32nd out of 38 countries. As in the previous year, Estonia, Latvia and New Zealand occupied the top three positions, while France, Colombia and Italy ranked lowest.

Poland's relatively low 32nd-place ranking is driven primarily by the low scores awarded to its taxation of consumption, where it ranks 36th, and property, where it ranks 29th.