Income taxes: changes in 2025

Monika Spotowska

26 August 2024

Information about the Finance Ministry working on a new bill has appeared in the official schedule of legislative and programme work.

The proposed solutions implement the programme agenda and are meant to tidy up tax regulations, clear out interpretation doubts and inconsistencies, and tighten up the tax system.

Changes to income taxes – FM proposes to:

state clearly that a taxpayer may deduct losses carried forward from the tax base for assessment of the solidarity tax;
refine and amend certain provisions concerning taxation of controlled foreign companies (CFC);
change the rules of determining revenues and expenses in case of a company merger without allotment of shares;
change taxation of family foundations;
change IP Box rules by introducing a requirement of employment;
change the solidarity tax rules – extend the base for assessment of the solidarity tax to include qualifying taxable IP Box income and beneficiaries’ benefits obtained from a family foundation;
change the rules of restructuring, i.e. company transformation, as well as reduction in share value or share exchange;
change the flat-rate taxation of income of a general partner in a limited partnership or a partnership limited by shares;
introduce regulations that refine flat-rate taxation of businesses to streamline this taxation regime;
change the restructuring regulations;
refine certain transfer pricing regulations.

The final shape of the regulations is unknown at this stage. The Council of Ministers is to adopt the planned changes still this year.

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Monika Spotowska

Attorney at law (Poland), Tax adviser (Poland)

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