Higher 22% corporate tax could also hit small firms, experts warn
From 2027 the Polish government wants to raise corporate income tax (CIT) from 19% to 22% for the largest firms. Experts quoted by Rzeczpospolita warn that restructuring rules could also catch small companies.
Author: Editorial teamPublished: 2 min read
A planned rise in Poland's corporate income tax (CIT) is meant to apply to the largest businesses, but some experts warn it could in practice also hit small companies. Rzeczpospolita reported this on 22 October 2026.
What the draft proposes
Prime Minister Donald Tusk said earlier that the government would propose raising CIT from 19% to 22% for entities with annual revenue above the equivalent of €50 million, or about PLN 200 million. The higher rate would also apply to tax capital groups. The changes would take effect in 2027. According to money.pl, the government adopted a draft amendment to the tax laws containing this at the end of September.
Where the "trap" lies
According to Rzeczpospolita, the problem lies in the rules on company restructuring. The Ministry of Finance says their purpose is to prevent avoidance of the 22% rate. Experts argue, however, that the higher tax could also be imposed on companies taking part in ordinary business reorganisation, and even on those with low revenue.
Piotr Stryjewski, a lawyer and tax adviser at the Paczuski Taudul firm, calls it a "blow to ordinary company restructurings", which he says are a perfectly natural part of doing business.
The part of the article that is publicly available does not describe the mechanism in detail, that is, which operations and under what conditions would lead to the higher rate. The full text is behind a paywall.
Wider context
The draft is part of a larger package of tax changes for 2027. According to money.pl, it also includes raising the second threshold in personal income tax to PLN 130,000, as well as changes to the solidarity levy and the flat-rate regime. A separate draft provides for a 30% CIT rate in 2027 for some large fuel, gas and energy companies.
Business organisations criticise the increase and say it will weaken firms' incentives to invest and hire. Analysts quoted by money.pl, by contrast, point out that the effective tax burden on companies in Poland is low compared with most EU countries.
The draft is not yet final, so the eventual shape of the restructuring rules may change during the legislative process.
Sources
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