Tax News

You will find here changes in the tax regulations discussed and commented by Forvis Mazars' experts.

Country-by-Country Reporting for the year 2024

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Pursuant to the exchange of tax information act, the Polish taxpayers belonging to large international groups are subject to additional obligations, such as reporting on entities which are part of the group (CbC-R) or indicating the entity in charge of delivering such information (CbC-P).

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Real estate tax changes in 2025 - what do you need to know?

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As of January 2025, significant changes have been made to Poland's real estate tax, which will have a major impact on entrepreneurs with extensive real estate and technical infrastructure.

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Transfer Pricing Adjustments in 2025 – Key Information and Practical Guidelines

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At the beginning of 2025, many taxpayers from international groups received transfer pricing adjustments for 2024, known as "tp adjustments." These adjustments raise questions regarding their compliance with Polish tax regulations. Therefore, before treating the adjustment as a transfer pricing adjustment and including it in tax-deductible costs or taxable revenues, it is essential to verify whether it meets all the requirements set in the Corporate Income Tax Act (hereinafter: CIT Act). Below, we present the key information and guidelines.

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JPK CIT obligation in a nutshell

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Based on the Regulation of the Polish Ministry of Finance published 29th August 2024, taxpayers will be obliged to produce and file “JPK CIT” – new standard audit files for CIT and fixed assets in required xml format. JPK CIT reporting will be additional to the standard annual CIT-8 return.

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Entry into force of the global minimum tax (Pillar 2)

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12 December 2024
On January 1, 2025, the Act on the so-called "top-up-tax" will come into force in Poland, introducing a new type of income taxation (global tax reform, the so-called "Pillar II", aimed at eliminating the transfer of profits to countries with low tax rates).

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Corporate Income Tax Adjustment for 2018 – final opportunity to recover overpaid tax

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10 December 2024
December 31, 2024, represents the statutory deadline for filing adjustments related to corporate income tax (CIT) liabilities for 2018. This is the last chance to submit an amended tax return for that period and secure the recovery of any overpaid tax.

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Another ruling by the Minister of Finance regarding exemption from withholding tax

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3 December 2024
General ruling of the Minister of Finance regarding the conditions for applying the exemption from withholding tax on the payment of interest and royalties within the EU/EEA

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Facilitating the exemption of dividends from withholding tax

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On November 15, 2024, the Minister of Finance issued a general tax ruling (ref.: DD9.8202.1.2024), which clarifies certain conditions for the application of the withholding tax exemption on the payment of dividends and other income derived from shares in the profits of legal entities to companies domiciled in European Union or European Economic Area. The purpose of this ruling is to standardize the application of the regulations by tax authorities and eliminate interpretative discrepancies.

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First settlement of the minimum income tax

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We would like to remind you that 2024 is the first period in which the so-called minimum income tax is in force. Therefore, the lapse of 2024 may mean that some taxpayers are obliged to settle this tax.

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