Poland Senate approves 22% corporate tax rate for large companies

Parliamentary passage is verified

The Senate’s official legislative record says the Sejm passed the bill on 5 November and the Senate adopted it without amendments on 6 November. The vote is a material legislative milestone, but the reviewed records do not establish presidential signature or promulgation. The proposed rate must therefore not yet be treated as operative law.^[1][2]

Two tests would bring taxpayers into the 22% rate

Article 2 of Sejm print 3323 would replace the 19% rate with 22% where a taxpayer’s revenue in the immediately preceding tax year exceeded the złoty equivalent of €50 million. It would also apply where the taxpayer was, at any point in that preceding year, a constituent entity of a domestic or multinational group within Poland’s top-up tax statute. The bill includes threshold adjustments for tax years shorter or longer than 12 months.^[3]

The group test connects to the top-up tax perimeter

Article 4 of the Act of 6 November 2024 generally brings a group within Poland’s top-up tax regime where consolidated annual revenue reaches at least €750 million in at least two of the four preceding tax years. That group-level test is distinct from the proposed €50 million entity-revenue test, so Polish entities need both screens rather than a single threshold check.^[3][4]

The bill points to tax years beginning after 2026

The transitional clauses would apply the corporate-tax provisions to income or revenue earned in tax years beginning after 31 December 2026, and the bill states that it would enter into force on 1 January 2027. Calendar-year companies would therefore first model 2027, while non-calendar-year taxpayers should test their own year start and the relevant preceding-year facts.^[3]

Enactment remains the focused gap

Groups can identify potentially affected Polish entities and model the proposed rate for forecasts, current-tax and deferred-tax analysis, but should not change returns or instalments on the assumption that 22% is enacted. Reopen the status when an official presidential decision or Journal of Laws publication confirms the final text, promulgation date and any changed commencement provision.^[1][3]