What has changed in the “Polish New Deal” package in comparison to its initial version?

Please find below our brief summary:


  • Introduction of so-called minimal tax (amounting to 10% of tax basis) for companies and tax capital groups (i) which incurred operational loss or (ii) in case of which ratio of operational income to operational revenues does not exceed 1%;
  • Decrease from 9% to 4.9% of non-deductible health insurance contribution for individuals carrying out business activity and subject to 19% PIT rate;
  • Local Transfer Pricing documentation will have to be prepared and submitted in electronic form only; the legislator resigned from the obligation to indicate within this documentation rules on participation of partners in profit and losses of tax transparent entities;
  • Simplification of conditions of Transfer Pricing corrections which result in the decrease of tax basis;
  • New regulation stating that indication of a person responsible to submit information on Transfer Pricing does not formally release the other board members from this obligation; 
  • Possibility to recognize as tax-deductible write-offs made on a separate fund for investment purposes created within the company’s reserve capital; this is limited to expenses made on the acquisition of new assets or development of new assets and fees incurred for repayment of their initial value excluding operational lease fees, expenses for cars and other expenses of “private” character;
  • Expansion of provisions of non-deductibility of “hidden dividend”;
  • Modification of local criteria of being a Polish tax resident – carrying out the tasks of the company on the territory of Poland in an “organized and permanent manner” will be decisive to recognize a given company as a Polish tax resident;
  • The extension (from 2 to subsequent 6 years) of the possibility to recognize for tax purposes costs of initial production of a new product when a taxpayer incurs a tax loss in the year when these costs are borne.


  • The taxable moment in case of transfer of ownership rights to goods as a result of indemnification will fall on the moment of receiving payment;
  • A new fine of PLN 5 000 for taxpayers who will not ensure proper cooperation of payment terminal with the fiscal online system.

We have already informed you about the “Polish Deal” package here.

In case of any questions, please feel free to contact our experts:

Łukasz Bączyk
Head of TaxBoard Member

Anna Szafraniec
CEE VAT Compliance Director

Jarosław Szajkowski
Tax Manager, Tax Adviser

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