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Polish tax changes in 2027 for companies and firms: bill status

On 22 October 2026 the Sejm passed a 12/24/32% PIT scale, a 250 000 euro ryczałt limit and Estonian CIT changes, and struck out 22% CIT. What happens in the Senate and what is already certain. Updated after every vote.

Category
Taxes
Updated
Author
Norman

On 22 October 2026 the Sejm passed all four government tax acts for 2027 (prints no. 3147, 3137, 3149 and 3148), but none is law yet: they wait for the Senate and the President. What matters most for firms: the Sejm struck 22% CIT for the largest firms out of the package, and kept the 12%, 24% and 32% PIT scale and the cut in the ryczałt limit from 2 000 000 to 250 000 euro.

Law as of 25 October 2026.

This article tracks the bills until the acts are published in the Journal of Laws (Dziennik Ustaw). After every vote we update the stage and add an entry to the history at the bottom of the page.

Status of the acts

PrintWhat it changesStagePlanned start
3147PIT scale 12/24/32% with threshold indexation from 2028, ryczałt limit 250 000 euro, 5% solidarity levy; 22% CIT struck outpassed by the Sejm 22.10.2026, in the Senate1 January 2027
3137Estonian CIT, 17% ryczałt on IP leased to a related party, 15% on rent from related parties above 100 000 zł, depreciation, car limitspassed by the Sejm 22.10.2026 without amendments, in the Senate1 January 2027, some provisions earlier
3149robotisation relief extended to 2036, expansion relief and internet relief abolishedpassed by the Sejm 22.10.2026 without amendments, in the Senate1 January 2027
3148taxation of family foundationspassed by the Sejm 22.10.2026, in the Senate1 January 2027

The Senate can accept the acts unchanged, amend them or reject them. It can also restore 22% CIT by an amendment; the Sejm then votes on that amendment again.

What is already certain for 2027

These rules follow from the law in force and do not depend on the bills.

What2027Legal basis
CIT rates for small taxpayers and others9% and 19%art. 19 ust. 1 ustawy o CIT
Small taxpayer limit (sales including VAT in 2026)8 754 000 złart. 4a pkt 10 ustawy o CIT
Tax on a shareholder's dividend19%art. 30a ust. 1 pkt 4 ustawy o PIT
Minimum wage4 950 złDz.U. 2026 poz. 1213
KSeFmandatory for everyone from 1 January 2027art. 145l–145n ustawy o VAT
Penalties for KSeF breachesin the law from 1 January 2027; a government bill (print no. 3245) moves them to 1 January 2028, but it is a billart. 106ni ustawy o VAT

KSeF for a company is covered in KSeF for a sp. z o.o., and the 9% and 19% rates in CIT 9% or 19%.

22% CIT: the Sejm struck it out

The government bill added a 22% rate to art. 19 ust. 1 ustawy o CIT for taxpayers with revenue above 50 000 000 euro in the previous year and for members of groups subject to the top-up tax. On 22 October 2026 the Sejm adopted a minority motion that deletes the whole CIT Act amendment (art. 2 of the bill), by 220 votes to 214. In the act as passed, the CIT rates stay at 9% and 19%. The Senate can restore the 22% rate by an amendment, and the Sejm then decides again. A small sp. z o.o. with revenue below 50 million euro stays at 9% or 19% either way.

PIT scale 12%, 24% and 32%

Annual incomeTodayAct passed by the Sejm
up to 120 000 zł12% minus 3 600 zł12% minus 3 600 zł
120 000–130 000 zł32% of the excess over 120 000 zł12% minus 3 600 zł
130 000–150 000 zł32% of the excess over 120 000 zł12 000 zł + 24% of the excess over 130 000 zł
above 150 000 zł32% of the excess over 120 000 zł16 800 zł + 32% of the excess over 150 000 zł

The scale applies, among others, to a management board member's salary under an employment contract and to entrepreneurs on the general rules (art. 27 ust. 1 ustawy o PIT). The maximum saving is 3 600 zł a year at income from 150 000 zł.

The government bill made the new scale depend on 22% CIT and the lower ryczałt limit taking effect (art. 5 ust. 2 of the bill). The Sejm struck that condition out together with 22% CIT, so the scale no longer depends on other changes. The Sejm also added yearly indexation of the scale thresholds by average annual inflation, when the index exceeds 100. The first indexation takes place in 2027 for 2028, using 2026 inflation; the Minister of Finance announces the thresholds by 30 November.

Ryczałt: a 250 000 euro limit and 17% above 300 000 euro

The act cuts the revenue limit for choosing the lump-sum tax on recorded revenue (ryczałt od przychodów ewidencjonowanych) from 2 000 000 to 250 000 euro (art. 6 ust. 4 and 6 ustawy o ryczałcie). On top of that, revenue above 300 000 euro a year would be taxed at 17%, with exceptions listed in the bill (new art. 12 ust. 1 pkt 1a). A sp. z o.o. does not pay ryczałt, but this change matters to entrepreneurs comparing a sole proprietorship (JDG) with a company. We compare the two in JDG or sp. z o.o..

Solidarity levy 5%

The levy on an individual's income above 1 million zł would rise from 4% to 5% (art. 30h ust. 1 ustawy o PIT). It would first apply to the levy due by 2 May 2028, that is on 2027 income.

The Sejm passed this act on 22 October 2026 in the committee report version (print no. 3224), without amendments. It bundles many smaller changes. For a sp. z o.o. the most important are:

  • Estonian CIT. Choosing the lump-sum tax on company income (ryczałt od dochodów spółek) in the middle of a tax year would no longer be possible, the employment condition is looser, and the act defines expenses unrelated to the business and clarifies hidden profits. Details in Estonian CIT.
  • Leasing a trademark or other IP to the company. A shareholder on ryczałt would pay 17% on revenue from a contract with a related party (today 8,5% up to 100 000 zł and 12,5% above). Exception: works protected by copyright.
  • Renting to the shareholder's company. Rental revenue from a related party above 100 000 zł would be taxed at 15% instead of 12,5%.
  • Depreciation. Depreciation rates for a given year could be raised or lowered no later than the filing deadline for that year's return. The limit applies to write-offs from 1 January 2027.
  • Passenger cars. The higher 150 000 zł limit for a combustion car with CO2 emissions below 50 g/km could also be proven with a document other than the CEPiK vehicle register entry, for example a certificate of conformity. This change would take effect on publication and apply back to 1 January 2026.

The Sejm passed this act on 22 October 2026 without amendments.

  • The robotisation relief (art. 38eb ustawy o CIT) would run until the end of the tax year starting in 2036 instead of 2026. The act also states expressly that for a fixed asset the qualifying cost is the depreciation write-offs.
  • The expansion relief (art. 18eb ustawy o CIT, art. 26gb ustawy o PIT) would be repealed. Costs incurred before 1 January 2027 stay under the old rules.
  • The PIT internet relief would be abolished, with rights kept for people who use it for the first time for 2026.

The act, passed by the Sejm on 22 October 2026, tightens the taxation of family foundations, among others on foreign income, short-term rental and the sale of assets contributed to the foundation. It concerns shareholders who moved their shares into a family foundation.

How a bill becomes law

  1. The Sejm passes the act in the third reading. All four acts reached this stage on 22 October 2026.
  2. The Senate has 30 days to accept the act, amend it or reject it (art. 121 ust. 2 of the Constitution). The Sejm can reject Senate amendments by an absolute majority.
  3. The President has 21 days to sign (art. 122 ust. 2 of the Constitution). The President can also refer the act to the Constitutional Tribunal or veto it.
  4. The Sejm overturns a veto by a 3/5 majority; the President then signs within 7 days (art. 122 ust. 5 of the Constitution).
  5. The act applies after publication in the Journal of Laws.

For provisions starting on 1 January 2027 the calendar matters: the Senate and the President together have up to 51 days, and a veto extends the procedure. The acts passed on 22 October fit this window unless there is a veto.

Example: what the acts change for a shareholder

A shareholder is the management board president on an employment contract with 140 000 zł of income a year. Privately, they lease a trademark to the company for 120 000 zł a year and pay ryczałt on it.

ItemTodayAfter prints 3147 and 3137
PIT on 140 000 zł of income10 800 zł + 32% × 20 000 zł = 17 200 zł12 000 zł + 24% × 10 000 zł = 14 400 zł
Ryczałt on 120 000 zł for the trademark8,5% × 100 000 zł + 12,5% × 20 000 zł = 11 000 zł17% × 120 000 zł = 20 400 zł
Total28 200 zł34 800 zł

The calculation is simplified: it leaves out ZUS contributions, deductible costs and the health contribution. It does show that the same package can lower one shareholder's tax and raise another's.

What you can do now

  1. Budget for 2027 at the rates in force and treat the changes passed by the Sejm as a scenario until the President signs them.
  2. If you are considering Estonian CIT from 2027, check the deadlines in Estonian CIT; after the changes in print 3137, joining mid-year would no longer be possible.
  3. If the company pays a shareholder for a trademark or rent, recalculate the contract at the print 3137 rates.
  4. Come back after the Senate vote: we will update the stage and the date.

Frequently asked questions

Will 22% CIT apply to my small sp. z o.o.?

No. The Sejm struck 22% CIT out of the act on 22 October 2026. Even in the government version the rate applied only to firms with revenue above 50 000 000 euro and to groups subject to the top-up tax. A small company stays at 9% or 19%.

Has the new 12/24/32% PIT scale been passed?

The Sejm passed it on 22 October 2026, but it is not law yet: the act waits for the Senate and the President's signature. The Sejm struck out the condition that tied the scale to 22% CIT, so the scale can take effect on its own.

When will the changes apply?

Most from 1 January 2027. Exceptions: the higher solidarity levy first applies to the payment due by 2 May 2028, and the CO2 evidence rules for cars from the day of publication, with effect from 1 January 2026.

Does the 250 000 euro ryczałt limit apply to a sp. z o.o.?

No. The lump-sum tax on recorded revenue is paid by individuals, for example in a JDG or a civil partnership (spółka cywilna). For a sp. z o.o. the relevant regime is the lump-sum tax on company income, Estonian CIT, which print no. 3137 changes.

How will I know the act has passed?

The Sejm publishes the stage of every bill on the print's page and in the legislative process record. We update this article after every vote and log the changes in the history below the text.

Changelog

  • October 2026: First version: prints no. 3147, 3137, 3149 and 3148 after first reading, in the Public Finance Committee.
  • October 2026: 25.10: the Sejm passed all four acts on 22.10.2026; from print no. 3147 it struck out 22% CIT and the condition on the new PIT scale, and added indexation of the PIT thresholds from 2028.

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