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

There is a shocking discrepancy between professional services firms’ parental leave packages. Those that fail to get with the times risk losing out in the war for talent
Winston Taylor is expected to launch in May 2026 with more than 1,400 lawyers across the US, UK, Europe, Latin America and the Middle East
They are alleging that leaked tax information ‘unfairly tarnished’ their business operations; in other news, Davis Polk and Eversheds Sutherland made key tax hires
Overall revenues for the combined UK and Swiss firm inched up 2% to £3.6 billion despite a ‘challenging market’
In the first of a two-part series, experts from Khaitan & Co dissect a highly anticipated Indian Supreme Court ruling that marks a decisive shift in India’s international tax jurisprudence
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
Gift this article