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March 4, 2024

Poland announces date of the planned implementation of Global Minimum Tax (Pillar 2)

  • The legislative process for implementing the EU directive on global minimum tax has been initiated in Poland.
  • It is intended that the relevant Act will be adopted in 2024 and be in force from 1 January 2025.
  • The draft bill is expected in March 2024.
  • The Polish administration intends to focus on introducing the Qualified Domestic Minimum Top-Up Tax in addition to adopting the Income Inclusion Rule and the Undertaxed Profit Rule.

According to information provided on the Poland government's website, the draft bill implementing the EU directive on global minimum tax (the Directive) has been added to the list of legislative processes in Poland. This confirms that the work on the draft bill implementing the Directive is at an advanced stage. The relevant Act is expected to be adopted in the third quarter of 2024 and be in force from 1 January 2025.

When implementing the Directive in Poland, the Polish administration intends to focus on introducing the Qualified Domestic Minimum Top-Up Tax (QDMTT) in accordance with the rules agreed within the Inclusive Framework, in addition to adopting the Income Inclusion Rule (IIR) and the Undertaxed Profit Rule (UTPR).

According to information that officials of the Ministry of Finance have conveyed in public speeches, a new Act separate from the Polish Corporate Income Tax (CIT) Act is intended to be introduced, comprising more than 100 pages of new legislation. The draft bill is expected to be published in March 2024. It is anticipated that the draft bill will be subjected to public consultations before it is sent to the Parliament.

Affected taxpayers should note that despite the delay in Polish implementation of the Directive (the deadline provided in the Directive expired at the end of 2023), Polish entities that are part of groups with annual consolidated revenues exceeding €750m may effectively be subject to global minimum tax obligations in the 2024 tax year due to regulations in force in other countries. This applies in particular to preparation of data needed to file a global information return.

Taking these developments into account, affected taxpayers will need to initiate analyses directed at establishing the obligations of Polish entities in relation to the global minimum tax system and estimating the impact of potential top-up tax. Additionally, the possibility of relying on Transitional Safe Harbors should be explored.

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Contact Information

For additional information concerning this Alert, please contact:

EY Doradztwo Podatkowe Krupa sp.k., Warsaw

Ernst & Young LLP (United States), Polish Tax Desk, New York

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

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