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Poland: New version of corporate income tax bill

Poland: New version of corporate income tax bill

A new version of a draft bill to amend Poland’s corporate income tax law (and also to amend the individual (personal) income tax law) was submitted on 4 October 2017 to the parliament.


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A main objective of the bill is to “tighten” the corporate income tax system so that the tax paid by large multinational enterprises is connected or linked to the actual location where the profits are derived—in particular by addressing and preventing the use of “aggressive tax planning” mechanisms.

Compared to the original draft version of the bill (presented in July 2017), certain measures have been liberalized—including the rules for thin capitalization and the taxation of intangible services. New provisions have also been introduced, including measures regarding debt push-down structures. 

Proposed changes

The proposed corporate income tax measures include:

  • Introducing two sources of income—one of a capital nature and the other on income of business activity and of special branches of agricultural activities
  • Changing the thin capitalization rules
  • Providing an exclusion from tax deductible costs, for interest on credits and loans incurred for the purpose of acquisition of shares in a company
  • Limiting the tax deductibility of payments for certain intangible services and fees for the use of copyrights, industrial property rights, or know-how
  • Modifying the tax rules for “tax capital groups”
  • Amending the rules for depreciation of intangible assets
  • Introducing a minimum tax on commercial property
  • Changing the controlled foreign company (CFC) rules
  • Revising the rules on the taxation of demergers
  • Broadening the scope of the real estate company clause to include almost all commercial entities and receivables
  • Introducing an economic substance (anti-avoidance) clause
  • Increasing the "one-off" tax depreciation threshold
  • Adjusting of the list of annual depreciation rates to the 2016 fixed assets’ classification

The amendments are anticipated to have an effective date of 1 January 2018.


Read an October 2017 report [PDF 350 KB] prepared by the KPMG member firm in Poland

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