Poland proposes 22% CIT rate for large taxpayers and tax capital groups

A renewed route for the CIT measure

The Council of Ministers adopted the bill by written procedure and sent it to the Sejm on 4 November. The Finance Ministry said the government used a separate bill after the Sejm removed the higher CIT rate from an earlier package and the Senate restored it on 27 October, creating procedural doubts that the new filing is intended to avoid. The measure is therefore a fresh legislative proposal, not an enacted rate change.^[1][2]

Proposed 22% rate

The proposal would increase the 19% CIT rate to 22% for taxpayers whose annual revenue exceeds the złoty equivalent of €50 million and for tax capital groups. The Ministry also describes changes to the lump-sum regime and solidarity levy, but those measures are not analysed here. This focused report does not treat one corporate-rate measure as a complete review of the mixed PIT, CIT and lump-sum package.^[2]

Parliamentary stage

The Sejm scheduled the first reading of print 3293 for 5 November and listed conditional Finance Committee consideration if the bill was referred. Those listings establish parliamentary handling, not passage. The Ministry presents the package as changes intended for 2027, but the operative commencement and transitional wording must be confirmed from the final enacted text.^[2][3]

What groups should do

Foreign-owned groups should identify Polish CIT taxpayers that may cross the stated revenue threshold and any entities within a Polish tax capital group, then model the proposed rate separately from current-law provisioning. No treaty-entitlement or cross-border allocation rule is changed by the submission itself. Groups should wait for parliamentary text and enactment before treating 22% as operative or changing return calculations.^[1][2][3]