Tax changes in Poland 2027 for businesses: what will change in PIT, CIT and lump-sum tax?

The planned tax changes in Poland 2027 include a new PIT scale, a 22% CIT rate for the largest taxpayers, restricted access to the lump-sum tax on recorded revenue and new taxation rules for certain related-party transactions. The revenue threshold for choosing the lump-sum regime is planned to fall from EUR 2 million to EUR 250,000, while revenue above EUR 300,000 would be subject to a 17% rate. The proposals also cover Estonian CIT, the solidarity levy, IP Box and depreciation. Most of the regulations are intended to apply from 1 January 2027, but the legislative process has not yet been completed.

Tax changes in Poland 2027 may significantly affect the way both sole traders and companies calculate their Polish tax liabilities. The Polish government has approved two packages of changes to PIT, CIT and the lump-sum taxation regime, which are intended to take effect from 2027. The first package was approved on 22 September 2026, while the second – covering, among other things, new PIT thresholds, a higher CIT rate for the largest taxpayers and restricted access to lump-sum taxation – was approved on 29 September 2026. Both bills have been submitted to the Sejm. For some businesses, this may make an early assessment of the potential impact through tax advisory services in Poland particularly important.

Although the changes are being processed through separate legislative packages, businesses should consider their combined potential impact on tax settlements from 2027. Particular attention should be paid to lump-sum taxation, related-party transactions, Estonian CIT and the taxation of entrepreneurs with high revenue or income. The new regulations may also require adjustments to accounting and reporting processes, increasing the importance of properly prepared accounting services in Poland.

---

What tax changes are planned in Poland for 2027?

The main proposed changes concern the PIT scale, the lump-sum tax on recorded revenue, CIT for the largest taxpayers, the solidarity levy and Estonian CIT. Some measures would increase tax burdens, while others are intended to clarify existing rules or remove current uncertainties.

The main proposals are summarised below:

Area	Planned change
PIT	12% threshold up to PLN 130,000, new 24% rate for income above PLN 130,000 and up to PLN 150,000, and 32% above PLN 150,000
Lump-sum tax – threshold	reduction of the revenue threshold from EUR 2 million to EUR 250,000
Lump-sum tax – high revenue	17% on revenue exceeding EUR 300,000
Lump-sum tax – related parties	17% on revenue from the rental of intellectual property between related parties and 15% on part of the revenue from the rental or lease of other assets
CIT	22% for the largest taxpayers and tax capital groups
Solidarity levy	ability to account for certain losses, inclusion of IP Box income and a planned increase in the rate to 5%
Estonian CIT	changes to settlement rules, hidden profits, the employment condition and formal requirements for choosing this form of taxation
Depreciation	new rules concerning, among other things, passenger cars and changes to depreciation rates

---

How will the PIT tax scale change in Poland in 2027?

The planned PIT reform would increase the first tax threshold from PLN 120,000 to PLN 130,000 and introduce an additional 24% rate. The 32% rate would apply only to income exceeding PLN 150,000.

Under the proposed rules, the PIT scale would be:

• 12% – for income up to PLN 130,000,
• 24% – for income above PLN 130,000 and up to PLN 150,000,
• 32% – for income above PLN 150,000.

The tax-free allowance is expected to remain at PLN 30,000. The Polish Ministry of Finance (MF) expects the change to reduce the sharp increase in the tax burden after taxpayers exceed the current PLN 120,000 threshold.

For entrepreneurs taxed under the progressive PIT scale, the change would mean incorporating the new parameters into advance tax calculations and comparisons of the available forms of taxation.

---

Will the CIT rate in Poland increase from 19% to 22%?

The planned increase in CIT to 22% would not apply to all companies. The higher rate is primarily intended for the largest CIT taxpayers.

Under the current proposals, the 22% rate would apply to taxpayers whose revenue in the previous tax year exceeded the equivalent of EUR 50 million, as well as to tax capital groups.

The proposal provides for an exemption for banks, which are subject to separate taxation rules. For other taxpayers that do not meet the scale-of-business criterion, the standard CIT rate would not be increased under this measure.

For international groups and larger companies operating in Poland, this means that the potential change may need to be incorporated into 2027 tax budgeting. Existing tax reporting models and effective tax rate forecasts may also require review.

---

Will the Polish lump-sum tax threshold be reduced to EUR 250,000?

This is what the current proposals provide for. The revenue threshold allowing an entrepreneur to choose the lump-sum tax on recorded revenue is planned to be reduced from EUR 2 million to EUR 250,000.

If the measure enters into force as proposed, eligibility for the lump-sum regime in 2027 will depend on revenue generated in 2026. A taxpayer whose revenue exceeds the equivalent of EUR 250,000 would not be able to choose this form of taxation for the following year.

The potential scale of the change is significant. According to Polish Ministry of Finance data for 2024, approximately 43,000 taxpayers using the lump-sum regime generated revenue exceeding EUR 250,000. Their total revenue amounted to PLN 102 billion.

For entrepreneurs whose revenue is close to the new threshold, this means that revenue generated during 2026 may determine which form of taxation is available in the following year.

---

When would the 17% lump-sum tax rate apply in Poland?

The proposed legislation contains two different mechanisms involving a 17% rate, and they should not be treated as the same rule.

The first would apply a 17% rate to revenue exceeding EUR 300,000 during the year. This measure is linked to restricting the use of lump-sum taxation by entrepreneurs generating high revenue.

In practice, an entrepreneur who meets the conditions for using the lump-sum regime at the beginning of the year would not automatically lose this form of taxation after exceeding EUR 300,000 in revenue. The amount above that threshold would, however, be subject to the 17% rate.

The second planned measure concerns transactions with related parties. The package approved by the government provides for a 17% lump-sum rate on revenue from the rental of intellectual property within such relationships. This includes structures in which a person related to a company makes certain rights available to that company and the company recognises the related expenditure. The Ministry of Finance presents this change as part of measures intended to restrict the use of rental and lease arrangements between related parties.

---

What will change for property rented to a related party in Poland?

The changes are also intended to cover the rental and lease of other assets between related parties.

In such cases, a 15% rate would apply to revenue exceeding PLN 100,000. The rule may be relevant, for example, where a shareholder rents property to their own company.

This distinction is important: the proposed 17% rate on revenue exceeding EUR 300,000 and the rates applying to related-party transactions arise from separate measures and concern different situations.

---

What will change under Estonian CIT in Poland?

The planned changes to Estonian CIT primarily concern the rules for choosing and applying the regime, hidden profits, non-business expenditure and the employment condition.

One of the significant measures is a planned relief for taxpayers that committed formal irregularities relating to the preparation of financial statements when choosing Estonian CIT.

The regulations are also expected to clarify rules concerning:

• switching to Estonian CIT,
• distributed income,
• hidden profits,
• expenditure unrelated to business activity,
• the employment condition.

For the employment condition, the proposal would allow partial employment under an employment contract to be combined with partial engagement under another type of contract.

For companies using Estonian CIT, a review of settlements with shareholders and other related parties will be particularly important. In practice, such benefits and transactions most often require analysis from the perspective of hidden profits or expenditure unrelated to business activity.

---

How will the solidarity levy and IP Box treatment change in Poland?

The proposed regulations also affect individuals earning the highest levels of income.

One of the packages would allow losses from previous years to be taken into account when calculating the solidarity levy base, provided that they relate to the relevant source of income. At the same time, income taxed under the IP Box regime would be included in the solidarity levy base.

A parallel proposal would increase the solidarity levy rate from 4% to 5%. It would continue to apply to the portion of the calculation base exceeding PLN 1 million.

For entrepreneurs using IP Box, this means that the preferential 5% tax rate on qualifying income may not represent the full tax burden associated with that income.

---

How will depreciation rules change in Poland from 2027?

The changes are intended to affect both the determination of limits for passenger cars and the ability to modify depreciation rates.

For passenger cars, the Central Register of Vehicles (CEP) would no longer be the sole source of CO₂ emissions data used to determine the applicable depreciation deduction limit. The measure is intended to reduce problems caused by incomplete or incorrect data held in the register.

The proposal also provides that, once the deadline for submitting the annual tax return has passed, taxpayers would no longer be able to retroactively decrease or increase the depreciation rates applied.

It is also planned to exclude the possibility of depreciating goodwill created when an enterprise or an organised part of an enterprise is made available for consideration under a finance lease.

---

Which businesses will be most affected by the tax changes in Poland 2027?

The scope of the planned changes is broad, but their impact will differ depending on the scale of the business, the form of taxation and the transaction structure.

The new regulations warrant particular attention from businesses and entrepreneurs that:

• currently use the lump-sum regime and generate revenue close to or above EUR 250,000,
• enter into rental, lease or intellectual property arrangements with related parties,
• use Estonian CIT,
• use IP Box,
• earn income subject to the solidarity levy,
• are CIT taxpayers generating revenue above EUR 50 million,
• belong to corporate groups that carry out transactions between related parties.

In these cases, the impact of the changes should not be assessed solely by reference to the nominal tax rate. Tax-deductible costs, health insurance contributions, available tax reliefs and the way transactions are settled across the group may also be relevant.

---

When are the tax changes in Poland 2027 expected to enter into force?

Most of the regulations described are intended to apply from 1 January 2027. However, the legislative process has not yet been completed, so the final scope of the new obligations will depend on the legislation ultimately enacted and published.

For businesses, this means that 2026 should be used to assess how the new rules may affect their operations, while decisions concerning tax settlements for 2027 should be based on the final wording of the legislation.

---

How should businesses prepare for the tax changes in Poland 2027?

The first step is to determine which of the proposed regulations actually apply to the business. For taxpayers using the lump-sum regime, revenue generated in 2026 will be critical. For larger companies, the level of revenue, the model used for related-party settlements and the applicable form of taxation will be particularly relevant.

Businesses should also review rental and lease agreements entered into with related parties, arrangements involving intellectual property rights and benefits or transactions between companies and their shareholders.

For more complex structures, it is worth assessing the combined impact of the changes across PIT, CIT, lump-sum taxation and other charges rather than analysing each regulation in isolation.

getsix® supports businesses in assessing the impact of tax changes and adapting their tax settlements to new Polish regulations. If you have questions about how the proposed rules may affect your business, please contact us regarding tax advisory services in Poland or accounting services in Poland.

---

Sources:

• Chancellery of the Prime Minister – draft amendments to PIT, CIT and lump-sum taxation approved by the Council of Ministers
• Ministry of Finance – changes concerning, among other things, Estonian CIT, rental, lease and depreciation
• Chancellery of the Prime Minister – planned changes to the PIT scale, CIT and lump-sum taxation

---

***