Poland approves tax changes: some businesses will pay more from 2027

The Polish government approved a large package of tax changes for entrepreneurs and companies on September 22. The draft affects the lump-sum tax (ryczałt), the IP Box relief, and the so-called Estonian CIT. Most of the new rules are planned to be introduced from January 1, 2027.

This is draft UD116, which the Ministry of Finance substantially rewrote several times over the past year. After consultations, the authorities abandoned some of the most stringent proposals, but the final government version reintroduced a number of measures aimed at limiting tax optimization.

One of the most notable changes concerns entrepreneurs who receive income from companies related to them. A ryczałt rate of 17% is to apply to income from renting or making intellectual property available to a related party—for example, when a trademark owner rents it to his own company. Currently, such schemes can be taxed at a significantly lower rate.

Separately, the rules for taxing ordinary rental between related parties are changing. For income above PLN 100,000, the rate is to be 15%. Under the current rules, for ordinary rental, income above this threshold is taxed at 12.5%. When renting property to an independent counterparty, the draft does not envisage raising it to 15%.

The changes will also affect specialists using the IP Box tax relief. Currently, it allows, subject to certain conditions, to pay 5% tax on income from qualified intellectual property—in particular, software. The government plans to include such income in the calculation of the solidarity levy for the highest-earning taxpayers.

The solidarity levy in Poland is 4% of the portion of an individual's relevant income exceeding PLN 1 million per year. Therefore, the change may primarily affect entrepreneurs and IT specialists with large incomes who simultaneously use the IP Box.

Another major block concerns the Estonian CIT—a regime where a company usually defers tax payment until profit distribution. The draft provides for a kind of amnesty for some companies that switched to this regime but, due to formal violations in preparing or signing financial statements, could lose the right to preferential taxation.

Also, from 2027, the authorities intend to abolish the possibility of switching to the Estonian CIT during an already started tax year. A company will be able to choose this regime from the beginning of a new tax period. The draft separately clarifies the rules for taxing profit after a company exits the Estonian CIT system.

The package is especially important for owners of small and medium-sized businesses who simultaneously run sole proprietorships and are co-owners of companies. It is the “entrepreneur—own company” models, renting property to related structures, and the use of certain tax reliefs that have become one of the main targets of the changes.

The government's approval does not yet mean the new rules will come into force. The bill must now pass the Sejm and the Senate, after which it will be sent to the President of Poland. Therefore, individual provisions and dates may still change during parliamentary consideration.

Based on materials from: Rzeczpospolita, Government of Poland — draft UD116, Chancellery of the Prime Minister of Poland