Poland

The Polish tax framework allows a notional interest deduction (NID) on equity capital, treating hypothetical interest as a tax-deductible cost without actual cash outflow. This mechanism benefits companies that retain earnings or receive capital contributions. Recent guidance clarifies the calculation methodology and highlights the potential for retroactive application to open tax years. Taxpayers should assess

On 1 September 2026, the Polish National Revenue Administration (KAS) issued a technical notice informing users of a planned maintenance window for the eUrząd Skarbowy (e-Tax Office) portal. The maintenance is scheduled for 1 September 2026 and may cause temporary disruptions to the availability of electronic tax services. Affected functionalities include submission of tax returns

On 31 August 2026, the National Revenue Administration (KAS) published its annual audit plan focusing on the protection and proper utilisation of public funds. The campaign prioritises high-risk areas including VAT carousel fraud, abuse of EU structural funds, and irregularities in public procurement contracts. KAS will deploy enhanced data analytics, cross-referencing taxpayer registers with banking

On 28 August 2026, the Ministry of Finance confirmed the creation of a single national database (EUREKA) for all individual tax interpretations issued by municipalities regarding local taxes and fees, particularly property tax (podatek od nieruchomości). Currently, over 2,400 municipalities publish interpretations on separate websites, leading to inconsistent rulings on identical issues, especially concerning new

The Supreme Administrative Court (NSA) ruled that the R&D tax relief (Ulga B+R) applies to the Tax Capital Group (PGK) as a single CIT taxpayer, not to individual member companies. This decision clarifies that the group, not its subsidiaries, is the entitled beneficiary. The ruling impacts how groups allocate and claim R&D expenditures, requiring consolidated

The Provincial Administrative Court (WSA) in Warsaw confirmed that the tax cost of shares acquired through a share-for-share exchange is the nominal value of the shares surrendered, not their issue price. This ruling affects corporate reorganizations and the calculation of taxable gains on subsequent disposal. The decision aligns with a literal interpretation of the CIT

The WSA in Gliwice upheld a restrictive interpretation of the real estate ratio under Article 3(3)(4) of the CIT Act. The ratio determines the portion of financing costs deductible for companies with significant real estate assets. The court affirmed that the calculation must follow strict statutory formulas, limiting the ability to adjust for specific asset

The Supreme Administrative Court ruled that taxpayers are entitled to statutory interest on tax overpayments resulting from reliance on an individual tax ruling later deemed flawed. The decision reinforces taxpayer protection under the Tax Ordinance, which was recently amended to strengthen such rights. The ruling clarifies that the tax authority bears the risk of erroneous