Polish Implementation of Global Minimum Tax – Implications for the Polish Entities and First Practical Observations!
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On March 1, 2025, the AmCham Tax and Financial Services Committee organized a meeting on the Polish Implementation of Global Minimum Tax.
Top-up taxation entered into force in Poland on January this year and according to the requirements, the capital groups with global consolidated revenues equal or higher than EUR 750 million are obliged to pay a top-up (supplementary) tax, if their effective tax rate (ETR) calculated according to a specific formula for operations in Poland, is lower than 15%. In addition to the risk of an additional tax burden, the new regime involves extensive analytical and reporting obligations. Furthermore, due to the tax benefits resulting from tax reliefs, top-up taxation is crucial for companies benefiting from such preferences, including investors enjoying CIT exemption in special economic zones/Polish Investment Zone or Research and Development tax credit.
Our speakers, experts from EY, an AmCham member company, presented the key principles of the new tax regime, including new mechanisms resulting from the Polish act, and commented on possible differences between the national standard and the OECD and EU models. We have discussed the requirements necessary for the calculation of top-up taxation (in full and simplified versions), potential sources of this data, and possible gaps. We also talked about obligations imposed on Polish entities and how to prepare for internal and external reporting, and discussions with auditors.
Thank you to our speakers, dr Filip Majdowski, Michał Koper, Hubert Rogoziński, FCCA, MRICS, Biegły rewident, and Agata Janas for your presentation, and to Adam Soska, the Chair of AmCham Tax & Financial Services, for moderating the discussion.
SPEAKERS
Filip Majdowski
Michal Koper
Hubert Rogoziński
Agata Janas
SPONSORS
Advisory Council
