Tax changes in 2025

While the beginning of 2024 seemed relatively “quiet” in terms of tax changes (apart from KSeF, which was initially set to launch mid-year), the last few months have been a wake-up call for many businesses. As we move into 2025, new reporting obligations, potential areas of increased tax burdens, and the ongoing trend of tax compliance digitalization will take center stage. Unfortunately, what we are missing this year is the promised six-month vacatio legis.

🎁 Check out 👉 The 2025 tax calendar

What should finance and tax teams pay special attention to in 2025?

Challenges related to the digitalization of tax reporting

JPK CIT

For fiscal years starting after December 31, 2024, the largest CIT taxpayers (with revenues over EUR 50 million and Tax Capital Groups) will be required to submit a report to the National Revenue Administration (KAS) in a new structured format (the JPK_KR_PD schema). This format will integrate data from accounting records with additional tax information.

The first reporting of fixed asset data (JPK_ST) will occur for fiscal years beginning after December 31, 2025. To avoid errors, accounting and tax systems should be adapted for compliance by January 1, 2025.

KSeF

Although KSeF (National e-Invoicing System) is set to launch in 2026, it should already be high on the priority list for CFOs, accounting teams, and tax managers in 2025. Our experience shows that this change impacts business processes beyond finance. While previous delays in implementation may cause skepticism, this change is strategic for all businesses and should be treated as a certainty. Any additional time should be well utilized for preparation.

Potential areas of increased tax burdens

Real estate tax redefined

Real estate tax, one of the most disputed taxes in Poland, will become even more complex in 2025. New independent definitions of "buildings" and "structures" have been introduced, along with clarified terms like "permanently attached to the land." Taxpayers must reassess their asset classifications and analyze the impact on their tax liabilities.

National minimum tax

In 2025, some businesses will calculate and pay the national minimum tax for the first time. This tax targets companies with operating losses or profitability below 2%. However, its calculation includes a range of data that could effectively minimize its impact.

Global minimum tax (GMT)

Poland's new legislation introducing the global minimum tax includes 164 articles spread over 80+ pages. For Polish companies that are part of international or domestic groups with consolidated revenues exceeding EUR 750 million, the introduction of GMT means:

- comprehensive calculations under new regulations,
- assessing the effectiveness of tax incentives (e.g., PSI or R&D relief),
- potentially paying a top-up tax to ensure CIT in Poland is at least 15%,
- preparing for complex tax reporting.

New data and reporting obligations

Reporting under GMT

One of the biggest international tax reforms of the last decade has finally been adopted in Poland, with a one-year delay. Starting in January 2025, Poland will introduce a new law on the equalization tax for constituent entities of international and domestic groups, accompanied by new reporting obligations.

While the exact template for Poland’s GMT return is not yet available, based on OECD standards and the draft DAC-9 Directive, fulfilling these obligations may require identifying nearly 480 data points and ensuring consistency across various organizational units.

CBAM

The Carbon Border Adjustment Mechanism (CBAM) imposes reporting obligations (effective October 2023) and, starting in 2026, additional charges for imports of products such as steel, aluminum, fertilizers, hydrogen, electricity, cement, and some derivatives. Starting in Q3 2024, importers must report actual embedded emissions data. Failure to meet these requirements may result in financial penalties or even the inability to import covered goods in the future.

EUDR

The European Deforestation-Free Regulation (EUDR) imposes obligations on businesses importing, trading, or exporting goods linked to deforestation (e.g., wood, rubber, palm oil, soy, coffee, cocoa). Non-compliance could lead to severe penalties or restrictions on business activities involving these products. If EUDR may affect your company, 2025 should be used to mitigate risks, starting with a detailed supply chain analysis.

Monitoring new and existing risks

Deposit system

Poland will introduce a deposit system in October 2025. While not strictly tax-related, its implementation raises tax challenges. If your business involves producing, importing, or trading beverages (e.g., juices, water, beer, energy drinks), it is crucial to analyze the VAT implications of the deposit system.

Withholding tax (WHT)

As of mid-2024, consultations with the Ministry of Finance regarding WHT guidelines are ongoing. Two general rulings on WHT exemptions under EU directives have been published. Unfortunately, these interpretations are not unequivocally favorable for businesses. 2025 will likely require thorough verification of WHT-related flows to mitigate risks associated with differing interpretations.