The due date for Polish minimum CIT is fast approaching

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

The due date for Polish minimum CIT is fast approaching

Sponsored by

sponsored-firms-mddp.png
Gdansk tower with clock

Konrad Medoliński of MDDP provides an overview of the key provisions governing the Polish minimum corporate income tax and highlights critical upcoming deadlines

Scope of application

The Polish minimum corporate income tax (CIT) applies to entities with Polish tax residency and domestic tax capital groups (TCGs) that, during a given tax year:

  • Incurred a loss from sources of income other than capital gains; or

  • Achieved a profitability ratio of 2% or less from sources of income other than capital gains.

The relevant legislation prescribes rules for calculating a loss for minimum CIT purposes, meaning an accounting loss does not necessarily trigger minimum taxation. The tax base calculation excludes several factors, including:

  • Tax depreciation costs;

  • Leasing costs; and

  • 20% of employment costs.

These adjustments may result in increased taxable income, potentially bringing the taxpayer's profitability established for minimum tax above the 2% threshold, thereby rendering the minimum tax inapplicable.

Payment deadlines

The minimum CIT is a one-time annual duty, with no requirement for advance payments throughout the tax year, with the following deadlines:

  • For taxpayers with a calendar-year tax period, the payment of the 2024 minimum CIT is due by March 31 2025; and

  • For taxpayers operating on a non-calendar tax year, the minimum tax must be paid by the end of the third month following the end of the tax year that commenced after January 1 2024.

Exemptions from the minimum CIT

There are statutory exemptions from minimum CIT. For instance, newly formed TCGs, recognised as distinct taxpayers, are exempt from minimum CIT obligations for three tax years: the year of establishment and the two subsequent years.

Additional minimum taxes

It is important to note that the Polish minimum CIT is not the only minimum tax relevant to enterprises, as there are, and will be, other ‘minimum’ taxes:

  • A minimum income tax on buildings, which has been in effect for several years;

  • Beginning January 2025, a global minimum tax that sets out top-ups to 15% will be implemented, with the option to also pay it in Poland for 2024; and

  • The tax on shifted profits, binding from 2022 and due on some payments to jurisdictions with lower tax rates.

Key considerations about the Polish minimum CIT

Given the upcoming deadlines for the minimum CIT payment, taxpayers are urged to assess their tax results promptly to determine applicability under the minimum income tax regime. This tax applies not only to entities reporting losses but also to those with special tax profitability below 2%.

more across site & shared bottom lb ros

More from across our site

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
Gift this article