Poland: Legislation amending corporate income tax measures in “Polish Deal” passed

Legislation must be signed by the president, amendments would become effective 1 January 2023

Legislation must be signed by the president

The Lower House of the Polish Parliament (the Sejm) passed legislation amending corporate income tax provisions enacted as part of the “Polish Deal.”

The legislation now must be signed by the president, and the 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 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 government on 28 June 2022 published proposed legislation that included amendments to the Polish Deal corporate income tax provisions. Read TaxNewsFlash
  • A draft bill including amendments to the Polish Deal corporate income tax provisions was submitted on 25 August 2022 before the Sejm. Read TaxNewsFlash

Summary of amendments

The key amendments under the legislation include:

  • Extension of exemption from (and modifications to) minimum income tax provisions
  • Repeal of hidden dividend regulations
  • Amendments to controlled foreign companies regime
  • Amendments to and clarification of provisions on profit sharing
  • Amendments to the withholding tax regime
  • Changes to deductibility of debt financing costs
  • Amendments to bad debt provisions (i.e., no requirement to enclose a special appendix to tax return)
  • Changes to holding company rules
  • Amendments to lump-sum taxation of corporate income provisions
  • Simplified procedure for refunding tax on revenue from buildings
  • Amendments to the provisions relating to requiring Local files for tax haven transactions
  • Changes to rules relating to obligation of entities required to submit transfer pricing reports to provide head office with information on contracts with non-residents
  • Introduction of interim provisions on calculating losses in companies belonging to tax groups
  • Change to first date for filing tax returns in the event of an earlier end of the tax year
  • Amendments to rules appliable to healthcare services
  • Clarification of rules on settling losses by tax group members

Read an October 2022 report prepared by the KPMG member firm in Poland


The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.