Only a few months have passed since the top-up tax (Pillar 2) regulations came into force (in Poland with a one-year delay as of 1 January 2025), and amendments to the Polish law implementing this regulation are already on the horizon.

On 7 April, the Polish Ministry of Finance published information on its website announcing work on a amendment bill. So far, the information about the changes is still quite general, but in principle they are to cover, among other things:

  • clarification of administrative regulations regarding the GloBE information return (GIR),
  • implementation of the January 2025 Administrative Guidelines regarding the recognition of deferred tax assets arising from tax credits received, and
  • clarification of the rules for profit allocation in the case of intermediate entities and allocation of taxes from the head office to the permanent establishment.

The Ministry of Finance also intends to clarify other regulations that have proven to be insufficiently precise.

The planned date for the adoption of the bill by the Council of Ministers is the third quarter of 2025.

Link: Draft bill amending the bill on compensatory taxation of constituent units of international and domestic groups and certain other acts - Chancellery of the Prime Minister - Gov.pl Portal

We will follow the legislative process and keep you informed of the proposed changes.

Przeczytaj w j. polskim: Pillar 2 – Już pierwsze zmiany do polskiej legislacji planowane