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Planned Changes in PIT and CIT

by Jan Starybrat

17 September 2025

A bill amending the income tax acts was published on 17 September 2025. The proposed measures aim at curbing some tax avoidance schemes identified by the revenue administration and sealing the taxation system.

The key measures are:

Limitations on disposal of after-lease movables within family – proceeds from sale of movables (e.g. a car bought out from lease) given to the business owner’s close family will be taxed if they are sold within 3 years.
Higher flat tax rate in the case of a hidden transfer of profits – remuneration paid by a company to shareholders and subject to flat tax on gross income will be taxed at an increased rate of 17%.
Revised depreciation and amortisation rules – among other things, limitations to amortisation of goodwill and no option to retroactively revise depreciation/amortisation rates after filing a tax return.
IP Box – the preferential tax rate of 5% will be available if at least 3 unrelated individuals are hired.
Business restructuring – new rules to restrict the use of business restructuring and liquidation for tax avoidance purposes.

The statute is to become effective on 1 January 2026. You can click this link to read the full bill. We will keep you posted on how the legislative work progresses and on details of the changes.

If you would like to discuss the potential implications of the novelties or get ready for the new rules already at this stage, we are at your service.

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Jan Starybrat

Attorney at law (Poland)

Senior Associate

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