Poland: Bill introducing VAT warehouse regime, altering purchase joint/several liability rules adopted by Council of Ministers; other tax developments

The KPMG member firm in Poland prepared a June 2026 report summarizing recent tax developments, including:

• KSeF consultations: The Ministry of Finance will hold consultations on June 9, 2026, regarding proposed changes to the national e-invoicing system (KSeF). Topics include revisions to business event models, API improvements, and rollout management.
• Family foundation clearance: The National Revenue Administration (KAS) issued a clearance opinion (June 3, 2026) validating the establishment of a family foundation and the contribution of private company shares. KAS confirmed the structure is not artificial and allows for various tax advantages, including a preferential 15% corporate income tax rate.
• Top-up taxation (global anti-base erosion (GloBE) law): A recent tax opinion clarified that entities connected through personal and equity ties—without an ultimate parent entity (UPE) or consolidated financial statement obligations—do not constitute a "group" under the Polish GloBE law, and for the €750 million threshold, only revenues from consolidated financial statements are considered.
• VAT on head office/branch transactions: The Supreme Administrative Court held that transactions between a foreign head office (that belongs to a VAT group in another EU member state) and its Polish branch (which is not in that VAT group) are subject to VAT, as the VAT group constitutes a separate taxable person.
• VAT Act amendments: The Council of Ministers adopted a bill introducing a VAT warehouse regime, altering purchaser joint/several liability rules, and updating taxpayer registration. The provisions are scheduled to become effective October 1, 2026.