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Good to know Amended GloBE Act – time for preparations

Amended GloBE Act – time for preparations

Print Mail Rate-it

​​​​​​​​​​by Maria Wośkowiak-Adamczyk

12 May 2025​

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The Ministry of Finance is working on amendments to the Act on top-up tax applicable to members of international and domestic corporate groups (GloBE). The amendments are key to entities being members of international structures and using tax credits.

GloBE Act – amendments


The amended Act is meant to implement the latest OECD Administrative Guidance of June 2024 and January 2025, as well as to clarify the existing provisions.  

Key areas to be amended concern, among others:

  • the method of recognition of deferred tax liabilities when the liability amount is not paid,
  • recognition of differences between values for GloBE purposes and carrying amounts,
  • the rules for allocation of head office’s taxes to permanent establishment,
  • more details on substitute tax credit asset and the introduction of rules for the recognition of deferred taxes to allocate taxes between entities,
  • clarification on how to recognise deferred tax assets arising from the received tax credits.

The bill is planned to be adopted by the Council of Ministers in Q3 2025.

DAC9


At the same time, the Council of the EU adopted DAC9 which facilitates global minimum tax reporting. DAC9 is closely related to GLoBE regulations and complements them by: 

  • providing a model top-up tax information return,
  • allowing the central filing of that return – international groups file the top-up tax information return only once in one Member State, which then transfers the relevant information to the relevant jurisdictions. ​

Now is the last moment to properly prepare for the upcoming changes and ensure full compliance with international guidelines.

If you are not sure whether GloBE regulations apply to your organisation, you are welcome to contact us​. We will be glad to conduct a first check analysis for you to assess the impact of the legislation on your tax accounts in Poland, and to outline a further action plan. Together, we will ensure that your accounts comply with laws and are safe tax-wise.

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Dominika Tyczka-Szyda

Tax adviser (Poland)

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Dorota Białas

Tax adviser (Poland)

Senior Associate

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