POLAND Trends and Developments Contributed by: Dawid Widzyk and Jan Jędrzejewski, V4 Tax sp. z o.o.
The effectiveness of tax audits should also increase within the new framework. Combating aggressive tax optimisation In 2025, two new institutions were established to com - bat aggressive tax optimisation – especially in the area of income tax. These are: • the Team for Combating Aggressive Tax Planning in Corporate Income Tax ( Zespół ds. zwalczania agresywnego planowania podatkowego w podatku dochodowym od osób prawnych ), established by the Ministry of Finance; and • the Competence Centre of the National Tax Admin - istration in Krakow ( Centrum Kompetencyjne Kra - jowej Administracji Skarbowej w Krakowie ). These specialised institutions are primarily focused on tax settlements of large entities, often having extensive international structures, which evade their tax obligations, in particular in relation to corporate income tax. Their establishment is a response to the growing issue of under-reporting income within the scope of transfer pricing. The Team operating at the Ministry of Finance focus - es, among other things, on the issue of transfer pric - ing as an instrument that is often used to artificially inflate or understate prices in transactions between related companies from different countries. The Team investigates cases where lower income is reported in Poland, resulting in lower tax payments to the Polish tax authorities. On the other hand, the Competence Centre is respon - sible for detecting and neutralising aggressive tax optimisation schemes. Its tasks primarily include: • analysing information about such schemes; • collecting and processing data from the JPK CIT and KSeF systems; and • preparing proposals for legal changes that would prevent the use of aggressive tax strategies. The ongoing digitalisation of tax settlements and the establishment of the aforementioned institutions should be seen as a signal, particularly for large enti - ties, to ensure correctness of their settlements and not
to neglect their transfer pricing obligations, as this is an area to which the Polish tax administration pays particular attention. In conjunction with the introduc - tion of the mandatory KSeF and the gradual expan - sion of JPK CIT obligations, possible irregularities on the part of taxpayers may be quite easily identified by the tax authorities. Amendments to the taxation of financial institutions Following legislative trends in some European coun - tries, Poland has also decided to introduce changes in the taxation of financial institutions from 2026, sig - nificantly complicating the regulations in this area. The changes primarily affect banks and credit institu - tions, but also co-operative savings and credit unions ( spółdzielcze kasy oszczędnościowo-kredytowe ). For CIT purposes, instead of the standard 19% rate previously applied, different rates will apply depend - ing on the type of financial institution. Ultimately, they will be: • 23% – for banks (domestic and foreign) and credit institutions, with certain exceptions; • 21% – for co-operative banks ( banki spółdzielcze ) and co-operative savings and credit unions; and • 11% – for the above-mentioned banks and institu - tions (with certain exceptions) whose revenues in the tax year did not exceed the equivalent of EUR2 million. It should be noted that these are target rates. Until 2028, there will be a transition period during which higher rates will apply, in some cases reaching up to 30%. The changes in rates will also be visible in the tax on certain financial institutions. From 2027, some taxpay - ers will be taxed at a new, reduced rate of 0.0329%, which will further decrease to 0.0293% in 2028. Additional matters Apart from the implementation of KSeF, the ongoing digitalisation process, combating aggressive tax opti - misation, and changes in the taxation of financial insti - tutions, there are also other areas that should attract taxpayers’ attention in 2026.
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