Poland · Administrative guidance
Poland publishes residual EU non-cooperative jurisdiction list
On 3 November 2026, Poland’s Minister of Finance and Economy published Notice No. 1080 identifying five EU-listed non-cooperative jurisdictions that are not included in Poland’s separate income-tax lists of harmful-tax-competition jurisdictions.
- Official document:
- Monitor Polski 2026, item 1080; notice dated 23 October 2026
- Development date:
- 2026-11-03
The notice was dated 23 October and published in Monitor Polski as item 1080. It was issued under Article 86a paragraph 8 of the Tax Ordinance. The annex names Guam, Palau, the Russian Federation, American Samoa and the Turks and Caicos Islands.[1][2]
A residual list, not the whole EU list
Notice No. 1080 does not reproduce every jurisdiction in Annex I of the EU list. It expressly covers EU-listed countries and territories that are not already included in the separate Polish lists maintained for personal and corporate income-tax purposes. The Council’s October update retained eight jurisdictions in EU Annex I; the Polish notice publishes the residual five falling within its stated formula.[1][2][3][4]
What the notice does not establish
The instrument is an official publication of the residual list, not an amendment to the Polish Corporate Income Tax Act or Personal Income Tax Act. It does not state a new tax rate, filing deadline, commencement rule or transaction-level consequence. Businesses should therefore not treat every listed jurisdiction as newly subject to every Polish anti-avoidance, transfer-pricing, withholding or controlled-foreign-company rule solely because the notice was published.[1][2]
Practical monitoring
Multinational groups with entities, counterparties, accounts or transactions connected to the five jurisdictions should flag the notice for legal and compliance review. The next step is to map Article 86a and the relevant income-tax provisions to the group’s actual facts before changing reporting, documentation or payment processes. That detailed application work remains separate from the verified publication milestone.[1][2]
The notice records that the relevant EU list was published in the Official Journal on 16 October 2026. Future changes to the EU list, the separate Polish domestic lists or the provisions that use them may alter the analysis, so tax teams should retain the exact notice date and list version in their compliance records.[1][3][4]
Official sources
- [1] Monitor Polski 2026, item 1080
Government Legislation Centre of Poland · Document date: 2026-11-03
Notice sections 1-2 and annex; publication metadata for Monitor Polski item 1080.
- [2] Official ELI text of Monitor Polski item 1080
Government Legislation Centre of Poland · Document date: 2026-11-03
Section 1 legal basis and residual-list description; section 2 EU-list publication reference; annex entries 1-5.
- [3] Council updates the EU list of non-cooperative jurisdictions for tax purposes
Council of the European Union · Document date: 2026-10-09
Updated Annex I jurisdictions and Council action dated 9 October 2026.
- [4] EU list of non-cooperative jurisdictions for tax purposes, C/2026/5413
Council of the European Union / Official Journal of the European Union · Document date: 2026-10-16
Annex I list published in the Official Journal on 16 October 2026.