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Poland: Proposals for amending corporate income tax law

Poland: Proposals for amending corporate income tax law

The Ministry of Finance has proposed measures that would affect Poland’s corporate income tax law and would transpose certain EU law measures (specifically EU directives about anti-tax avoidance and concerning the automatic exchange of financial account information) into Polish law.


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Among the proposals in Poland are measures to provide for:

  • Preferential taxation of income generated by intellectual property rights (the “innovation box” regime), with a 5% rate of tax on income received by taxpayers from qualified intellectual property rights that are created, developed or improved by the taxpayers within their research and development activities
  • A reduced corporate income tax rate of 9% for taxpayers with revenues (other than capital gains) not exceeding for a preceding tax year the PLN equivalent of €1.2 million 
  • A notional interest deduction 
  • New solutions for trading packages of receivables, by allowing the recognition of a cost base of a specific receivable and implementation of new rules concerning packages of receivables when one packet includes at least 100 receivables
  • The introduction of an alternative method of bonds taxation
  • Measures to tax revenue from cryptocurrency trades as capital gains
  • Changes increasing the allowance for passenger car depreciation 
  • Allowing certain tax deductions with respect to debt-to-equity swaps 
  • The introduction of an “exit tax” (at a rate of 19%) on the transfers of certain assets or for a change of tax residency
  • Changes regarding obligations concerning withholding tax 

The measures are subject to changes during the legislative process, and are proposed to be effective 1 January 2019.


Read a September 2018 report [PDF 370 KB] prepared by the KPMG member firm in Poland

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