Poland: Template for GloBE information return; other tax developments
Other tax developments include various legislative developments and Supreme Administrative Court decisions
may 26, 2026
The KPMG member firm in Poland prepared a May 2026 report summarizing recent tax developments, including:
- Statutes passed by the Senate: The upper house of Parliament (Senate) on May 21, 2026, passed several statutes without amendments, including the Act on the Crypto-Assets Market (implementing EU Regulation 2023/1114), the Act amending the Tax Code and Fiscal Criminal Code (regarding the statute of limitations for tax liabilities), and the Act amending the Act on the Gift and Inheritance Tax (extending the tax exemption for gifts made to flood victims until December 31, 2026). The Senate also passed amendments to the Act introducing over 50 amendments to the tax code (including an increase of the limit of tax payable by an entity other than a taxable person from PLN 1,000 to PLN 5,000) and the Act adjusting the legal framework for the publication of individual tax rulings. The amendments will be put to a vote in the lower house of Parliament (Sejm).
- Pillar Two developments: The Ministry of Finance published a template for the global anti-base erosion (GloBE) information return (GIR-1) and a list of jurisdictions with qualified agreements on information exchange.
- Preliminary remarks on windfall tax bill: Preliminary remarks to a bill on windfall profits generated in 2026 from the manufacture and trading of certain liquid fuels were added to the list of legislative work for the Council of Ministers on May 19, 2026. The bill would introduce a levy on entities earning excess profits and is anticipated to be approved by the Council of Ministers in the second quarter of 2026.
- Value added tax point for ongoing legal services: The Supreme Administrative Court on May 19, 2026, held that ongoing tax advisory services provided under continuous-term contracts qualify as ongoing legal services, meaning the VAT point is at the time the invoice is issued.
- Lump-sum tax on general partners’ profit shares: The Supreme Administrative Court on May 19, 2026, held that the right to claim a tax credit for tax paid by a limited partnership is determined by the person’s status as a general partner at the time the profit is distributed, not by the duration of their membership during the tax year.
- Invoicing comprehensive services: The Supreme Administrative Court on May 20, 2026, held that when a comprehensive service is rendered and transport is necessary for the supply of goods, transport costs remain part of the taxable amount for the supply and are subject to the same VAT rate, even if shown separately on the invoice.