Poland: Proposed legislation includes amendments to “Polish Deal” corporate income tax measures

The proposed amendments would become effective 1 January 2023.

The proposed amendments would become effective 1 January 2023.

The government on 28 June 2022 published proposed legislation that would amend corporate income tax provisions enacted as part of the “Polish Deal.”

The Polish Deal refers to legislation amending the income tax laws affecting corporations and individuals, as well as the value added tax (VAT) and other tax legislation, which was passed on 29 October 2021 and is generally effective as of 1 January 2022. Read TaxNewsFlash

The proposed amendments would become effective 1 January 2023, except for provisions relating to requiring Local files for tax haven transactions, which would become effective as of the day of announcement. 

The proposed amendments include: 

  • Modification and postponement of minimum income tax provisions
  • Change of the date of updating individual taxpayer data
  • Repeal of hidden dividend regulations 
  • Amendments to regulations on controlled foreign companies (CFCs)
  • Amendments to provisions on profit shifting taxation
  • Amendments to the withholding tax regime
  • Changes to the method of charging debt financing costs into tax-deductible costs 
  • Changes to regulations on initial public offering (IPO) relief
  • Simplified regulations on bad-debt relief 
  • Amendments to the provisions on the Polish holding company regime
  • Amendments to the provisions on lump-sum tax on corporate income
  • Amendments to the provision on the deadline for remitting premiums arising from the receivables from service relationship and equivalent, in the part financed by the tax remitter, premiums paid to the Labor Fund, the Solidarity Support Fund, and the Guaranteed Employee Benefits Fund
  • Changes to the provisions on the refund of tax on revenue from buildings
  • Amendments to the provisions on the obligation of documenting tax haven transactions
  • Clarification of provisions on the scope of the Minister of Finance’s duties in terms of providing return templates 
  • Clarification of the obligation of entities bound to submit transfer pricing reports to provide the head of office competent for the taxpayer with information on contracts with non-residents
  • Amendments to provisions relating to healthcare services 
  • Clarification of provisions on settling losses by tax group members
  • Clarification of the rules relating to statements and applications submitted by taxpayers for the purpose of collecting tax advances

Read a June 2022 report prepared by the KPMG member firm in Poland


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