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Pillar 2 – Disclosures in 2025 financial statements

​The first reporting on top-up tax for 2025 will not be required until 2027. However, the 2025 financial statements already have to include the amounts of potential global tax, domestic tax and tax on undertaxed profits.


Importantly, statutory auditors will expect these figures during the financial statement audit. To make the required disclosures, your company should know:


  • whether it belongs to a group that is subject to Pillar II regulations;
  • which top-up tax collection mechanism may apply in Poland;
  • whether it can make use of transitional safe harbours or other exemptions;
  • and if not – the amount of potential tax.

We would be glad to assist you in:


  • obtaining the information from your group;
  • assessing the availability of the exemptions and safe harbours;
  • simulating the local top-up tax burden, including calculation of the provision for that tax;
  • drafting the relevant disclosures in the financial statements.

You are welcome to contact us.​


Author: Dorota Białas

11 December 2025


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Dorota Białas

Tax adviser (Poland)

Senior Associate

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