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

What the government proposes for 2027 (22% CIT, a 12/24/32% PIT scale, a 250 000 euro ryczałt limit, Estonian CIT, the robotisation relief), where each bill stands and what is already certain. Updated after every vote.

Category
Taxes
Updated
Author
Norman

As of 10 October 2026, none of the government's tax changes for 2027 has been passed: the bills in Sejm prints no. 3147, 3137, 3149 and 3148 have had their first reading and are waiting in the Sejm's Public Finance Committee. The proposals that matter most for firms are 22% CIT for revenue above 50 million euro, a PIT scale of 12%, 24% and 32%, and a cut in the ryczałt limit from 2 000 000 to 250 000 euro.

Law as of 10 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 bills

PrintWhat it changesStagePlanned start
314722% CIT for the largest taxpayers, PIT scale 12/24/32%, ryczałt limit 250 000 euro, 5% solidarity levyreceived 29.09.2026, first reading 6.10.2026, in committee1 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 limitsreceived 24.09.2026, first reading 6.10.2026, in committee1 January 2027, some provisions earlier
3149robotisation relief extended to 2036, expansion relief and internet relief abolishedreceived 29.09.2026, first reading 6.10.2026, in committee1 January 2027
3148taxation of family foundationsreceived 29.09.2026, first reading 6.10.2026, in committee1 January 2027

The committee is the Komisja Finansów Publicznych (FPB). None of the bills has reached the Senate yet.

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; the announced deferral is so far only a Ministry of Finance statementart. 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 for the largest taxpayers

The bill adds a new pkt 6 to art. 19 ust. 1 ustawy o CIT: a 22% rate. It would cover:

  1. taxpayers whose revenue in the previous tax year exceeded the equivalent of 50 000 000 euro (NBP rate of the last working day of that year, rounded to 1 000 zł);
  2. taxpayers that in the previous year belonged to a group subject to the top-up tax (the global minimum tax), whatever their own revenue.

The 22% rate would also apply for 3 years to companies after a division, merger or contribution of a business, if it concerns at least 10% of assets (proposed art. 19 ust. 1i and 1j). A small sp. z o.o. with revenue below 50 million euro stays at 9% or 19%.

PIT scale 12%, 24% and 32%

Annual incomeTodayBill
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.

An important condition that many summaries leave out: the new scale only works if 22% CIT and the lower ryczałt limit also take effect on 1 January 2027 (art. 5 ust. 2 of the bill). If those provisions fall, the scale stays as it is.

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

The bill 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.

This bill 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 bill 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 robotisation relief (art. 38eb ustawy o CIT) would run until the end of the tax year starting in 2036 instead of 2026. The bill 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 bill 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 Public Finance Committee prepares a report, then the Sejm holds the second and third readings.
  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.

Example: what the package would 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 bills as a scenario.
  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 Sejm vote: we will update the stage and the date.

Frequently asked questions

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

No, if its revenue in the previous year did not exceed 50 000 000 euro and it does not belong to a group subject to the top-up tax. A small company stays at 9% or 19%, and this is only a bill anyway (print no. 3147).

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

No. The bill had its first reading on 6 October 2026 and is in the Public Finance Committee. The new scale only works together with 22% CIT and the lower ryczałt limit (art. 5 ust. 2 of the bill).

When would 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.