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On 16 March 2026, the Government Legislation Centre website published a Ministry of Finance bill of great importance to Polish business, amending the Personal Income Tax Act, Corporate Income Tax Act and Act on Lump-Sum Income Tax on Certain Revenue Earned by Individuals. Major PIT, CIT and lump-sum changes are drawing closer and, under the bill, much is to enter into force on 1 January 2027. Today we present selected planned changes most important to entrepreneurs under different Polish tax regimes.
CIT and PIT Act amendments — our 10 most important changes for entrepreneurs and companies: Estonian CIT, IP Box, housing relief, depreciation and more
Most proposed changes concern the CIT and PIT Acts, some both together.
Below is our subjective list of the 10 most important:
- Extensive changes to Estonian CIT, particularly:
- No choosing Estonian CIT during the tax year;
- A new definition of non-business expenditure;
- Expanding hidden profits;
- Liberalising the employment condition;
- CIT new definitions of small taxpayer and entity starting activity , the latter excluding entities continuing another entity’s enterprise or organised part;
- Excluding hidden dividend expenditure from tax-deductible costs under CIT;
- Restricting tax-free sale of a leased asset after gifting it to close family: currently possible six months after the gift, but the proposal extends this to three years;
- Housing relief only once every three years;
- Treating datio in solutum, discharge of debt through a different performance from that initially agreed, as disposal for consideration;
- IP Box changes:
- Extending the solidarity levy to IP Box income;
- Introducing an employment requirement for IP Box;
- Prohibiting depreciation rate changes after the deadline for filing that year’s return;
- Prohibiting real estate depreciation for real estate companies;
- Prohibiting goodwill depreciation when an organised part of an enterprise is accepted for use under leasing.
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Proposed lump-sum tax changes — 17% and 15% rates
The main changes under the bill amending the PIT, CIT and Lump-Sum Income Tax Acts also include amendments for taxpayers using lump-sum tax on registered revenue.
Here there are only three changes:
- Extending the 17% rate to revenue from rental, lease or similar agreements with related entities concerning intellectual property or similar products, excluding copyrighted works;
- A 15% rate on rental revenue exceeding PLN 100,000 from related entities;
- A 15% rate on revenue exceeding PLN 100,000 from services currently taxed at 8%, where at least one employee is not employed.
If this article interested you, explore our tax advisory services and read how we can help you:
Summary
Major CIT, PIT and lump-sum tax changes in 2027? The Council of Ministers adopted the bill
The bill amending the PIT, CIT and Lump-Sum Income Tax Acts, extremely important for Polish business, was published on the Government Legislation Centre website on 16 March 2026.
It proposes major changes for CIT, PIT and lump-sum taxpayers. The most important are to enter into force on 1 January 2027. Until then, we undertake to follow this and other important bills carefully, so no regulatory changes surprise our Clients or Readers!
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