Status of legislative work
On October 22, 2026, the Sejm passed six bills constituting the government tax package, which is expected to enter into force on January 1, 2027. The Senate considered it on October 27, 2026.
PIT scale, lump sum and CIT 22% (form no. 3147)
The new wording of Article 27, Section 1 of the Personal Income Tax Act introduces a three-step scale: 12% up to PLN 130,000, 24% on the excess over PLN 130,000 to PLN 150,000, and 32% on the excess over PLN 150,000. The maximum savings will be PLN 3,600 per year. Furthermore, the solidarity levy rate is increasing from 4% to 5% – the higher rate will apply to payments in 2028.
Among the controversial changes, the revenue limit entitling one to the lump sum tax on recorded revenues has been reduced from EUR 2,000,000 to EUR 250,000, which at the NBP exchange rate from October 1, 2026, corresponds to PLN 1,094,250. Because the limit applies to the previous year's revenues, the 2026 revenues will determine the eligibility for the lump sum tax in 2027.
Sealing Act (Form No. 3137)
Lump-sum income from rental, lease and intellectual property licenses (excluding works) obtained from a related entity will be subject to a 17% rate, and income from rental from such an entity exceeding PLN 100,000 will be subject to a 15% rate.
In the Estonian CIT system, Article 28j, paragraph 5 of the CIT Act, which required the preparation of a financial statement when choosing the lump sum tax during the year, was repealed. Article 5 of the amending act provides for an amnesty for taxpayers whose right to the lump sum tax was questioned for this reason. At the same time, the concept of hidden profits has been extended to include benefits covered from profits from before the lump sum period, and Article 30a, paragraph 19a of the PIT Act eliminates double taxation of a partner in the event of a lump sum payment under Article 28h, paragraph 4 of the CIT Act.
The Act also introduces the right to change depreciation rates until the deadline for submitting the tax return and a closed list of reductions to the solidarity levy base.
Family foundations (form no. 3148)
The tax rate on family foundation benefits increases from 15% to 19% for benefits provided from the foundation's tax year beginning after December 31, 2026. The list of hidden profits will include unrepaid loans, ten-year loans to individuals, and forgiven and time-barred receivables.
The exemption from Article 6, Section 1, Item 25 of the Corporate Income Tax Act will not apply to the lease of residential premises, unless the foundation rents them directly and exclusively for residential purposes, which it must prove, nor to the lease of 24-hour accommodation facilities, which has previously been the subject of disputes with tax authorities. Furthermore, a two-year grace period has been introduced for the sale of contributed assets. Foundations will be subject to the provisions on controlled foreign entities and exit tax.
The personal income tax exemption has been extended to include descendants of the founder's siblings and stepson and their descendants. The transitional provision of Article 3, paragraphs 4 to 7 of the amending act allows for the tax-neutral return of residential real estate to the current owner until December 31, 2027, with the obligation to supplement the founding capital up to PLN 100,000 if the returned property covered it.
Reliefs (form no. 3149)
The internet tax relief is being repealed, with the deduction for 2027 retained for taxpayers who first use it in 2026. The expansion tax relief is being repealed, with the existing provisions applying to costs incurred before 2027. The robotization tax relief is being extended until 2036, and the deduction for honorary blood donation will be calculated on the doubled amount of compensation.
Excise and VAT (forms no. 3136 and 3135)
From January 1, 2027, the excise tax rate on ethyl alcohol will be PLN 10,109.00 per hectolitre of 100-proof alcohol, PLN 13.82 per hectolitre per degree Plato for beer, and PLN 280.83 per hectolitre for wine. Any surplus revenue over the 2026 level will increase the National Health Fund subsidy from 2029. An amendment to the VAT Act exempts non-alcoholic beer, de-alcoholized beverages, and beverages with caffeine or taurine from the reduced rate.
At this point, the shape of the bills depends on the Sejm vote and the President's decision. Flat-rate taxpayers whose income in 2026 may exceed PLN 1,094,250, family foundations operating leases or planning distributions, and taxpayers with income exceeding EUR 50 million should review their situation before the end of the year, as some of the effects of the new regulations depend on events occurring in 2026. We will keep you updated on the future developments of the proposed changes.
This article is for informational purposes only and does not constitute legal advice.
The law is current as of November 2, 2026.
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