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2025 brings important changes to the Polish tax system. The new rules
will cover family foundations, tax capital groups, businesses
using cash-basis accounting and other significant issues related to taxes and
local charges. Below we discuss the most important changes taking effect at
the start of the new year to help businesses prepare for
the upcoming rules.
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1. Family foundations: proposed tax changes
Although a formal bill concerning family foundations has not yet been presented, public consultations on proposed changes are under way. These are the main proposals under discussion:
- CIT of 19% on the sale of assets contributed less than 15 years earlier. The CIT paid would be deducted from the 15% CIT charged on payments to beneficiaries. - CFC rules: introduction of provisions covering income of family foundations from interests in tax-transparent entities. - Taxation of income from property rental. - Penalties for unauthorised activities, currently taxed at 25%. The proposal would leave the decision to dissolve a foundation conducting unlawful business to the court. - Solidarity levy: benefits to beneficiaries would be subject to 4% tax when a beneficiary's annual income exceeds PLN 1 million.
2. JPK CIT: new obligations and reporting structures
From 1 January 2025, an extended JPK_KR_PD will be mandatory. It will replace the existing JPK_KR and introduce additional identifiers (“tags”). The new JPK-ST-KR structures will apply: - From 2025: to tax capital groups and taxpayers whose revenues exceeded EUR 50 million in the previous year. - From 2026: to PIT and CIT taxpayers submitting JPK VAT.
- From 2027: to other PIT and CIT taxpayers.
3. Minimum CIT
The new minimum tax provisions have applied since 2024, but their effects will be felt in settlements for 2024. This tax applies to companies that have not achieved a minimum profit margin of 2%. Exemptions will cover: - Companies with a simple ownership structure. - Entities meeting the conditions for special exemptions, such as a drop in revenues or an occasionally low profitability rate.
4. Global top-up tax (Pillar 2)
The bill awaiting government adoption concerns corporate groups whose consolidated revenues exceed EUR 750 million. The reform forms part of BEPS 2.0, which seeks to prevent erosion of the tax base and profit shifting. A top-up income tax will be payable if the effective tax rate in a jurisdiction is below 15%.
5. Cash-basis PIT for sole proprietors
From 1 January 2025, sole proprietors whose revenues do not exceed EUR 250,000 can use cash-basis PIT. This arrangement: - Removes the need to adjust PIT under bad debt relief after 90 days. - Improves liquidity when customers pay late. Bear in mind, however, that this method increases the cost of accounting services, as accounting firms will have to handle additional settlements linked to payments received. Businesses wishing to use it must file the appropriate declaration with the tax office by 20 February.
6. New definitions of a building and structure
Changes to the Local Taxes and Charges Act introduce new definitions of a building and a structure, which may affect their taxation.
7. Excise duty increases
2025 will bring higher excise duty on certain products, including tobacco products.
8. VAT exemption for small businesses
New EU provisions adopted by the government include a VAT exemption for small businesses throughout the European Union.
9. Health insurance contribution changes
At the end of October, the government adopted a draft of health contribution changes. Under the proposed provisions, proceeds from sales of fixed assets will not be included in the calculation base. A reduction is also planned for businesses taxed under the general rules (progressive income tax). The contribution will be calculated on 75% of the minimum wage.
If you found this article interesting, explore our tax advisory services and read how we can help you:
Summary
Upcoming changes in tax regulations require businesses
to prepare carefully. Both the new rules on family foundations and
changes to tax reporting or health contributions may affect
daily operations. It is worth analysing ahead of time what steps to take to
comply with the new rules and avoid unpleasant surprises. It is worth discussing the effect of the new rules on our business with an experienced tax adviser, who will certainly point out appropriate solutions in the coming year.
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