Since 2025, a fresh 15% minimum taxation has been in force to reduce taxation competition and make a fairer taxation strategy in the associate States of the European Union. The introduction of this taxation is part of an EU initiative to destruct aggressive forms of taxation optimisation.
Why was the minimum taxation introduced?
According to KPMG's analysis, the minimum taxation is simply a consequence to global corporate taxation avoidance challenges. Transfer of profits to another jurisdictions costs EU countries billions of euros per year. The introduction of a minimum rate of 15%, in line with the EU guidelines, is intended to reduce specified practices and strengthen the state budget.
New regulations
The fresh regulations include the alleged Pillar II of global taxation rules aimed at eliminating aggressive forms of taxation optimization. They supply for 3 types of compensatory taxes:
* Oh, my God * National taxation on income of low-taxed units in Poland.
* Global taxation applicable to capital groups whose units operate in countries without adequate regulation.
* taxation on undertaxed profits charged to parent companies in capital groups operating in jurisdictions without minimum taxation.
Who is covered by the fresh regulation?
The minimum taxation applies to companies accounting for CIT, which have achieved low profitability or reported losses. According to the Ministry of Finance data, as many as 32% of the companies analysed meet these criteria. This means that over 1,300 companies will gotta face fresh requirements.
Tax exemptions
The provisions supply for many exceptions to the request to pay minimum tax. The commitments will not include, inter alia, banks and financial institutions, hospitals and wellness care facilities, municipal businesses, start-ups in the first 3 years of business, tiny taxpayers with revenues below EUR 2 million, entities in bankruptcy or liquidation, companies that have achieved at least 2% profitability in 1 of the last 3 years.
How is the minimum taxation calculated?
The minimum taxation will be 15% of the taxation base, which will include 1.5% of the company's revenues, debt financing costs, the costs of intangible services and royalties paid to affiliated entities that exceed certain limits. Alternatively, taxpayers can choose a simplified counting mechanism, where the rate is 0.3% of revenue.
What does that mean for companies?
The Ministry of Finance assumes that the fresh taxation will contribute to sealing the taxation strategy and expanding the gross for the budget. Companies will gotta analyse their financial strategies in item to avoid additional burdens. Low profitability companies may face the request to restructure or change their financial policy to adapt to fresh requirements.
Introduction of grants
The Ministry of improvement and Technology is preparing a fresh investor support strategy for the introduction of a global minimum tax. conventional taxation exemptions which have so far attracted companies to peculiar economical zones in Poland will be replaced by cash grants. The fresh strategy assumes an individual approach to each investment and the amount of support will depend on a number of factors specified as the scale of the planned investment, the location of the project, the strength of regional aid and the fulfilment of certain quality criteria.
The introduction of a minimum taxation is simply a step towards a more equitable taxation strategy in Poland. Although this change represents fresh challenges for businesses, it besides aims to destruct unfair competition and increase budgetary revenue.
More here:
Minimum taxation 2025: What does it mean for companies in Poland?
