We would like to present you a short, original summary of important tax and business law topics in 2025. This applies to both changes in tax law and other important issues. It is worth analyzing them in terms of their impact on your business.
Pillar II “minimum” tax
From 1 January 2025, the provisions of the act implementing Council Directive (EU) 2022/2523 into the Polish legal system are to enter into force.
It introduces a minimum tax addressed to international and local capital groups with an annual global turnover of more than EUR 750 million.
Its role is to ensure that such entities settle the tax at the level of at least 15%.
For now, the bill is waiting for its adoption by the Sejm, while the final shape of the regulations should be known before the end of the year.
SAF_CIT
In 2025, regulations introducing the obligation to report SAF_CIT will be in force.
SAF_CIT assumes reporting of accounting books in two schemes (JPK_KR_PD – accounting records, JPK_ST_KR fixed asset records).
In accordance with the provisions of the respective regulations, it will be mandatory to send SAF_CIT files after the tax year following the date:
- 31 December 2024 – in the case of:
- tax capital groups,
- taxpayers and companies which are not legal persons, whose revenue earned in the previous tax year or financial year, respectively, exceeded the equivalent of EUR 50 million converted into PLN at the average EUR exchange rate announced by the National Bank of Poland on the last business day of the previous tax year or financial year, respectively;
- December 31, 2025 – in the case of taxpayers and companies that are not legal persons, obliged to send the (SAF) JPK_V7M file;
- December 31, 2026 – in the case of other taxpayers and companies that are not legal persons.
In practice, this means that for the largest taxpayers and tax capital groups whose tax year begins on 1 January 2025, the first SAF_CIT reporting will take place by 31 March 2026. and will include data for 2025.
At the same time, a provision is currently being processed in the Sejm, according to which the Minister of Finance may issue a regulation to exempt taxpayers from the obligation to provide records of fixed assets and intangible assets (JPK_ST_KR files).
Property tax
From 2025, the property tax regulations will also change. Although the legislative process is ongoing, the final version of the regulations should already be known.
The most important change is the clarification of the definition of buildings and structures – the need for changes after the judgment of the Constitutional Tribunal. The building is to be a structure erected as a result of construction works, together with installations ensuring the possibility of its use as intended, permanently attached to the ground, separated from the space by building partitions, and which has foundations and a roof.
On the other hand, a building will not be considered a facility used to collect materials, the basic technical parameter of which is capacity (e.g. a tank).
The draft act contains a closed catalogue of structures subject to taxation (e.g. specified in the annex to the act, specific construction parts of structures or foundations).
At the same time, the catalogue of taxable construction equipment has been narrowed down to only those that are directly related to the building or structure and necessary for their intended use.
The so-called small architecture objects are to remain outside taxation.
In addition, the amendments provide for clarification of the rules for taxation of garages in residential buildings with real estate tax – they will be considered as a residential part of the building and the scope of the real estate tax exemption for port infrastructure structures – it has been decided that the real estate tax exemption applies to port infrastructure structures in seaports or marinas (including infrastructure structures that provide access to seaports or marinas and land occupied for them).
At the same time, it is proposed to extend the possibility of submitting property tax declarations by entrepreneurs until 31 March 2025 to give them time to adapt to the proposed changes.
Changes in PIT and CIT
According to the Government’s announcement, from 2025 an amendment to the PIT and CIT regulations is to be introduced, concerning:
- IP Box – The government planned to introduce regulations excluding the use of the IP Box by sole proprietorships;
- family foundations – the announcement indicated that the planned changes would introduce a transitional period that the foundation would have to undergo in order to benefit from the 15% CIT rate when transferring its assets to beneficiaries;
- solidarity levy – the legislator intended to cover both income from IP BOX and beneficiaries of family foundations with a 4% solidarity levy;
- general partners in limited partnerships – the changes were to concern the rules for calculating the lump-sum income tax on the general partners’ income.
However, at the moment, there is no draft law on the above changes, which raises justified doubts as to whether the changes will be able to enter into force at the beginning of 2025.
KSeF
Currently, it is proposed that the mandatory KSeF will enter into force in stages:
- 1 February 2026 for entrepreneurs whose sales value (including the amount of tax) exceeded PLN 200 million in 2025;
- 1 April 2026 for other entrepreneurs.
Thus, 2025 should be the year of preparation for implementation into the mandatory KSeF.
At the moment, we are waiting for the ministry’s legislative proposals, including the next version of the schema or the announced simplifications.
CSRD
The draft act implementing the CSRD directive was submitted to the Sejm on 9 October.
Let us remind you that, in some simplification, this is about reporting specific ESG information.
According to the bill, the reporting regulations are to enter into force on 1 January 2025.
The Act introduces an obligation for entrepreneurs to report results related to sustainable development in accordance with ESG standards. According to the provisions of the implemented directive:
- from 2025 The reporting obligation will apply to large entities employing more than 500 employees and meeting one of the following criteria: balance sheet total exceeding EUR 50 million or net sales revenues exceeding EUR 25 million;
- from 2026 The reporting obligation will apply to other large entities employing more than 250 employees and meeting one of the following criteria: balance sheet total exceeding EUR 50 million or net sales revenues exceeding EUR 25 million.
- from 2027 The reporting obligation will be extended to small and medium-sized entities with the possibility of postponing data collection and reporting until 2028 and 2029, respectively, employing at least 10 employees and meeting one of the following criteria: balance sheet total greater than EUR 450 thousand or net sales revenues greater than EUR 900 thousand.
“Cash” PIT
From 1 January 2025, the regulations on “cash” PIT will apply. It will be available to taxpayers whose income is not more than EUR 250,000. Cash PIT will be limited in time for a period of 2 years. An entrepreneur who decides to use cash PIT in 2025 will have to submit a statement to the tax office that he intends to settle in this form.
New limits
The tax limits for 2025 for the status of a small taxpayer in PIT and CIT and for a small VAT taxpayer are already known.
As a reminder, the status of a small taxpayer in the context of income tax is granted to entities whose value from sales in the previous year did not exceed the equivalent of PLN 2 million. euro. The conversion of this limit into the Polish currency is made according to the average EUR exchange rate announced by the National Bank of Poland, effective on the first working day of October of the year preceding the tax year, rounded up to PLN 1000.
Therefore, the status of a small taxpayer under PIT and CIT in 2025 will be used by a taxpayer whose sales value (including VAT) in the previous year did not exceed PLN 8,569,000.
On the other hand, the status of a small taxpayer in VAT will be granted to a taxpayer whose sales value (including the tax amount) did not exceed in 2024. PLN 8,569,000.
Other
- It is possible that changes in the health insurance contribution will be adopted – probably no contribution obligation for the sale of fixed assets. So far, however, there are no legislative details.
- Exemption from the obligation to fiscalise – we are waiting for the adoption of a new regulation, the obligation to cover, among others, from April 2026 parking services.
- Changes in VAT – adoption of the so-called SME package – including the application of an exemption due to the level of turnover for EU taxpayers and the extension of the reverse charge mechanism for gas or energy, as well as changes in the application of rates for certain goods.
- E-deliveries – from 1 January 2025, selected professions of public trust and newly registered companies will be required to have an address for e-Deliveries. Existing companies will be obliged to do so from 1 April 2025.
