The latest Poland Barometer by TMF Group (Q3 2025) examines how cash-basis PIT, the national e-invoicing system (KSeF), the labour inspectorate reform, higher CIT for financial institutions and the expansion of the SENT transport-monitoring system will affect profitability, liquidity and tax–accounting processes for companies operating in Poland.
Positive or neutral changes (and announcements) for doing business in Poland
More firms to benefit from cash-basis PIT
In August 2025, the Government Legislation Centre published a draft amendment to extend access to cash-basis personal income tax (PIT). From January 2026, the revenue threshold for using the cash method would rise from PLN 1 million to PLN 2 million. Many more micro and small businesses could then recognise income tax only upon actual receipt of payment, rather than on invoice issuance.
Cash-basis PIT, in force since 2025, is gaining traction as it helps protect liquidity and reduces the risk of paying tax on unpaid invoices—especially relevant in services and retail, where payment bottlenecks remain common.
“This is one of the few changes that truly improves day-to-day settlements for the smallest firms. Doubling the threshold signals that lawmakers are starting to understand micro-business liquidity realities. For many companies it’s not just administrative relief but a safer way to plan tax,” says Magdalena Grzegorczyk, TMF Group expert.
KSeF: a reform to tidy up tax settlements
In August 2025, the President signed the National e-Invoice System (KSeF) Act. Mandatory use starts in February 2026 for large companies, April 2026 for others, and January 2027 for the smallest taxpayers.
KSeF introduces a real-time, standardised e-invoicing model, enabling faster fraud detection and tightening the VAT system. For businesses it promises automated document flows and fewer errors and delays. A new “offline24” mode will allow invoices to be sent on the next business day—helpful for firms outside major cities.
“KSeF is a milestone in digitising state–business relations. After years of testing, Poland joins countries that have cut the VAT gap with e-invoicing. Done right, it can streamline processes, automate accounting and enhance tax certainty,” says Mikołaj Ślusarek, TMF Group expert.
(Challenges tied to KSeF are discussed later.)
Labour Inspectorate reform: more transparency and digitisation
Announced in September 2025 for rollout in 2026, the reform of the National Labour Inspectorate (PIP) would overhaul oversight of labour law. Inspectors would be able to reclassify civil-law contracts into employment contracts, conduct remote inspections, demand electronic documents, and take witness statements online. Higher penalties—up to PLN 60,000—aim to deter abuses. Digitised procedures should accelerate case handling and improve data use.
“This direction can clean up the labour market and reward compliant employers. Digital inspections and administrative reclassification tools can curb bad practices. Firms acting lawfully should benefit from a level playing field and greater employee trust,” says Anna Jendo, TMF Group expert.
(Risk aspects of the reform are discussed later.)
A new “security” investment relief
In September 2025, the National Chamber of Tax Advisers proposed a new tax incentive—the Security Relief—for both businesses and individuals, allowing deductions of up to 200% of costs that improve operational, infrastructure and cyber security. Companies could carry forward unused relief amounts for six years. The proposal reflects rising geopolitical risks and the growing weight of cyber-resilience and infrastructure robustness.
“It’s a relief with potential—aligning state and business interests. In today’s environment, security is part of economic stability. The key is to avoid bureaucratic drag so the relief genuinely stimulates investment,” says Magdalena Grzegorczyk.
Good news for exporters outside the EU
On 1 August 2025, the CJEU ruled that intra-EU supplies later exported outside the EU may still qualify for VAT exemption even if the supplier did not know about the extra-EU export—provided material conditions (actual export) are met. This prioritises substance over formalities and should reduce disputes and sanctions for documentation gaps.
“A long-awaited dose of common sense. If goods truly left the Union, taxpayers shouldn’t be punished for paperwork gaps. This strengthens exporters’ legal security,” says Mikołaj Ślusarek.
Company mergers: clearer tax-neutrality rules
Since September 2025, CIT rules clarify that mergers without issuing shares in the acquiring company are income-tax-exempt if one shareholder owns all shares in the merging entities or shareholders hold them in the same proportion. The Ministry promises consistent administrative practice and fewer interpretation disputes.
“Clarifying neutrality signals stability and can unlock M&A, especially in sectors needing capital and scale,” notes Mikołaj Ślusarek.
CIT and the Tax Ordinance: a move toward presumption of innocence
In September 2025, the Senate Budget and Public Finance Committee backed a CIT amendment removing the requirement for holding companies to pre-declare their intention to use the capital gains CIT exemption on share disposals. It also supported Tax Ordinance changes embedding a presumption of innocence in ex officio tax proceedings—placing the burden of proof on authorities and resolving irresolvable factual doubts in favour of the taxpayer, with three exceptions (conflicting party interests, statutory burdens on the party, overriding public/state interest).
“This is a philosophical shift—away from default suspicion toward administrative responsibility. It treats entrepreneurs as partners, not potential offenders,” says Mikołaj Ślusarek.
Demanding changes (and announcements) for doing business in Poland
Deposit-return system: logistics and tax complexity
Launched on 1 October 2025, Poland’s deposit-return system covers plastic bottles, cans and glass. While VAT clarifications arrived in late August, uncertainties remain around income tax treatment and compensation for retailers and producers. New administrative duties—deposit ledgers, JPK reporting, handling surplus returns—are especially heavy for retailers and smaller chains.
“The idea is right, but the timetable is risky. Companies must operate amid interpretive uncertainty, which raises costs and error risk,” warns Mikołaj Ślusarek.
Cutting tech incentives: IP Box limited to employers
A 16 September 2025 tax amendment would restrict access to preferential regimes, including the IP Box. Using the 5% rate would require employing at least three unrelated individuals. Many sole-trader programmers—previous key beneficiaries—would lose eligibility.
“Curbing abuse is understandable, but this also hits genuine value-creators in IT and could hurt Poland’s tech competitiveness,” says Magdalena Grzegorczyk.
Presidential veto on Tax Ordinance changes
At end-August 2025 the President vetoed a bill to update the Fiscal Penal Code and Tax Ordinance—key to the government’s deregulation push. The package sought more proportional sanctions for minor mistakes and simpler procedures for unintentional errors. The veto prolongs a strict, often impractical regime.
“A setback for simplification. Business expected smarter rules, not a freeze of the status quo,” says Magdalena Grzegorczyk.
Higher CIT for banks and financial institutions
A government draft would raise CIT from 19% to 30% for banks, credit institutions and credit unions starting 2026, with gradual cuts to 26% (2027) and 23% (2028). The bank asset tax would be reduced by 10% in 2027 and 20% in 2028. The Finance Ministry cites defence funding needs. The sector warns of lower profitability, potential pass-through to customers and slower investment in financial services.
“Costs may be passed on through higher fees and margins; longer term it could weigh on financing capacity. Tax hikes shouldn’t be the only budget tool,” notes Magdalena Grzegorczyk.
Labour Inspectorate reform: risk of paralysis and uncertainty
Employers fear 2026 changes allowing administrative reclassification of civil-law contracts into employment contracts with immediate effect, higher fines (to PLN 60,000), broader powers and remote hearings. Absent precise criteria, decisions may become discretionary, raising costs (ZUS, taxes) and legal risk.
“The new powers go far. Clear drafting is essential to protect workers while preventing overreach and ensuring legal certainty for firms,” says Anna Jendo.
KSeF: a digital revolution that may strain businesses
From 1 February 2026 all Polish businesses must receive invoices via KSeF—even if they don’t issue them there. Many will need ERP upgrades, staff training and integration testing. Despite a transition period, advisers warn some firms won’t be ready; connectivity outages and throughput in large groups remain open questions.
“Necessary, but the pace is too fast. For big companies it’s months of heavy work; for small ones, serious organisational stress. Early-phase errors, fines and system overloads are real risks,” says Mikołaj Ślusarek.
Tightening the Estonian CIT
With over 20,000 users, the Estonian CIT is set for tightening. The Finance Ministry plans to broaden the notion of “hidden profits” (e.g., rents, advisory fees, licences and other related-party transactions), tax any profit distribution upon exit from the regime, and refine the definition of non-business expenses. A modest simplification would ease formalities for signing financial statements.
“The regime was meant to be simple and pro-growth; continual tweaks make it less predictable and invite disputes over interpretation,” says Magdalena Grzegorczyk.
SENT transport monitoring: a puzzling expansion
A September 2025 regulation expands the SENT system—previously covering fuels, alcohol, tobacco and chemicals—to include concrete and selected footwear and apparel goods from 2026. Companies in these sectors must confirm receipt in the system; failure may trigger fines. For many SMEs this means new admin burdens and IT investments.
“While aimed at sealing VAT leakage, the expansion increases bureaucracy and costs—especially for industries new to this regime,” says Magdalena Grzegorczyk.
Source: CEO.com.pl – “13 kluczowych zmian dla biznesu w Polsce w Q3 2025: podatki, administracja i cyfryzacja.”
