Poland has implemented Global Minimum Tax (Pillar 2) legislation, introducing new top-up tax calculation rules and related reporting and data collection obligations.
Who is affected?
Developed by the OECD and the G20, Pillar 2 aims to ensure a minimum effective tax rate of 15% in each tax jurisdiction. As a general rule, the regulations apply to multinational and domestic groups with consolidated revenues of at least EUR 750 million in at least two of the four preceding fiscal years. They may affect both parent entities and Polish subsidiaries. The EU framework is based on Directive (EU) 2022/2523, implemented in Poland by the Act of 6 November 2024.
How does GloBE work?
The GloBE (Global Anti-Base Erosion) framework determines whether a group’s effective tax rate in a given jurisdiction is at least 15%. If it is lower, a top-up tax liability may arise. The calculation requires specific adjustments to financial and tax data.
What obligations may apply to Polish companies?
Depending on the group, these may include:
- assessing whether the relevant regulations apply;
- collecting and reconciling financial and tax data;
- calculating the effective tax rate and any top-up tax;
- preparing and filing the GloBE Information Return (GIR) and relevant tax returns, and paying any tax due.
For groups first applying the Polish rules for 2025 whose fiscal year coincides with the calendar year, the key deadlines are 30 June 2027 (GIR) and 30 September 2027 (top-up tax return and, where applicable, payment).
How ACS can support you
Together with our business partners, ACS offers:
- assessment of Pillar 2 applicability and potential tax liabilities;
- review of data, obligations, and deadlines;
- support with GloBE calculations and reporting;
- assistance in adapting internal processes and ensuring tax compliance.
Contact us: apietrasik@acs-group.pl
