The approaching end of the year is a good time to prepare for the upcoming tax changes, of which there are countless every year. 2025 will be no exception. What changes can be expected in corporate income tax?
JPK_CIT
Businesses have become accustomed to submitting the Standard Audit File (SAF-T) containing VAT information. 2025 will be the first year for which CIT information will also be required to be reported in the SAF-T file. SAF-T_CIT will be sent annually, by the end of the third month following the end of the tax year. Therefore, the first SAF-T file must be submitted by the end of March 2026. However, the mandatory implementation of SAF-T_CIT is being phased in. CIT taxpayers with income exceeding €50 million and tax capital groups are required to submit it first (report for 2025). Subsequently, other CIT taxpayers who submit SAF-T_VAT (report for 2026) will be required to submit SAF-T_CIT for 2027.
Entities required to report for 2025 will be required to include in the logical structure of their accounting records the tags identifying the accounts contained in the appropriate dictionary, which is an annex to the Regulation of the Minister of Finance on additional data to be added to accounting records subject to reporting under the Corporate Income Tax Act. From January 1, 2026, JPK_CIT will also include the following information: the contractor identification number, the invoice identification number in the National e-Invoice System, and the amount, type, and nature of the difference between the balance sheet result and the tax result.
We remind you that family foundations are also subject to CIT. They will therefore be required to submit JPK_CIT.
National Minimum Tax
In 2025, the obligation to pay a minimum (national) tax will arise for the first time. This tax will amount to 10% of the tax base. This base will be the sum of:
1) an amount corresponding to 1.5% of the value of revenues from sources of revenue other than capital gains earned by the taxpayer in the tax year, and
2) debt financing costs incurred for related entities in the part in which these costs exceed the amount calculated according to the formula provided in the Act, and
3) costs of:
a) advisory services, market research, advertising services, management and control, data processing, insurance, guarantees and sureties, and similar services, and
b) all kinds of fees and charges for the use or the right to use copyrights, licenses, industrial property rights, and know-how, and
c) transfer of the risk of debtor insolvency under loans, other than those granted by banks and cooperative savings and credit unions, including liabilities arising from derivative financial instruments and similar services, incurred directly or indirectly for the benefit of related entities or entities with their place of residence, registered office, or management board in a tax haven
– in which these costs in total in the tax year exceed by PLN 3,000,000 the amount calculated according to the formula provided in the Act.
CIT taxpayers with unlimited tax liability in Poland (i.e. having their registered office or management board in the territory of the Republic of Poland) who incurred a tax loss in 2024 or whose income was lower than 2% of revenue will be obliged to pay the minimum tax.
The minimum tax must be reported in the annual CIT return. It is payable to the tax office on the same date as the "traditional" income tax. The minimum tax amount may be reduced by the CIT income tax.
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European minimum tax
From 1 January 2025, the Act on Equalisation Taxation of Component Units of International and Domestic Groups will come into force, introducing the so-called global minimum tax.
The equalization tax will apply to the largest domestic and international business groups, meaning those generating global revenues exceeding €750 million annually. The condition for payment of this tax is that they pay income tax at an effective rate below 15%. The tax does not assume a fixed tax rate, but rather is a compensatory tax. Taxpayers will be required to pay it in an amount that brings the effective income tax rate and the global minimum tax to a combined 15%.
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This article is for informational purposes only and does not constitute legal advice.
Legal status as of December 6, 2024
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