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Pillar 2 – local obligations and responsibility in global structures

by Dorota Białas

3 July 2025

The Act on Top-Up Tax Applicable to Constituent Entities of Multinational Enterprise Groups and Domestic Groups of 6 November 2024 (the so-called Top-up Tax Act), implementing Pillar 2 of the BEPS 2.0 initiative developed by the OECD, has been in force in Poland since 1 January 2025.

What should Polish entities pay special attention to?

Local responsibility – it is the Polish companies that are responsible for correct tax accounting and for the completeness and quality of the data submitted to the tax administration.
Insufficient data in the head office – a parent company with a registered office abroad may lack some of the data needed to comply with the obligations under the Polish legislation, including the data necessary to calculate the due tax.
Active management – a Polish company should be able to assess its own tax and reporting obligations.

Comprehensive support for companies operating in Poland

In response to these challenges, we offer our clients comprehensive support tailored to the situation of their Polish companies operating within international corporate groups, including:

a preliminary analysis of the situation ("first check"),
assessment of obligations and risks,
support in communication with the head office and preparation of documentation.

We will answer your questions and present specific scenarios tailored to your group’s structure and the current stage of preparation for implementation of the legislation. Contact us »

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Dorota Białas

Tax adviser (Poland)

Senior Associate

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