Poland: Proposed amendments to income tax regulations; other tax developments
Proposed income tax changes, reporting updates, power of attorney revisions, and court decisions affecting corporate income tax and VAT
september 2, 2026
The KPMG member firm in Poland has prepared an August 2026 report summarizing recent tax developments, including:
- Income tax amendments proposed: A draft bill would extend the robotization relief for an additional 10 tax years, increase the blood donation deduction limit, and repeal the Internet relief and expansion relief under both individual income tax and corporate income tax. The measures are proposed to become effective on January 1, 2027.
- Consultation on tax reporting taxonomy changes: The Ministry of Finance is consulting on proposed additions to the tax tag dictionary (PD) and new RPD reporting fields intended to better capture differences between accounting and tax results, including for entities reporting under IFRS.
- New power of attorney forms proposed: A draft regulation would introduce revised tax power of attorney forms effective on October 1, 2026, reflecting Tax Code amendments and expanding the ability of certain non-parties to appoint representatives in tax proceedings.
- GAAR clearance issued for share redemption transaction: The Head of the National Revenue Administration concluded that a planned voluntary redemption of shares without consideration was supported by valid business purposes and was not primarily tax-driven, confirming that the general anti-avoidance rule (GAAR) would not apply.
- SAC clarifies initial adjustment rules for Estonian corporate income tax: The Supreme Administrative Court (SAC) held that taxpayers that elected Estonian corporate income tax before January 1, 2022, remain subject to the initial adjustment rules in force before the 2022 amendments.
- SAC confirms timing of VAT liability for continuous license services: The SAC held that VAT liability arises at the end of the contractual settlement period and is not deferred by a later sales report from a counterparty, even when the report is needed to calculate the final fee.
- SAC addresses hidden profits under Estonian corporate income tax: The SAC held that loans and related financing payments involving related parties may constitute hidden profits for Estonian corporate income tax purposes regardless of whether the terms are consistent with the arm's-length principle.