Scheduled for 5 November 2026 in Warsaw, the “BEPS 2.0 w praktyce” (BEPS 2.0 in Practice) event focuses on the practical implementation of the Global Minimum Tax (Pillar Two) in Poland. The Polish legislature published a draft amendment to the Equalization Tax Act on 5 February 2026, transposing the EU Directive (EU) 2022/2523. Combined with ongoing OECD administrative guidance, Polish multinational enterprises (MNEs) and domestic groups face urgent compliance obligations for fiscal years starting 2024/2025. The event covers qualifying domestic minimum top-up tax (QDMTT), income inclusion rule (IIR) mechanics, safe harbor elections, data collection for GloBE returns, and integration with existing CIT processes.
Key Takeaways
- Transposition Nuances: The Polish draft law introduces specific elections and simplifications (e.g., transitional CbCR safe harbor) that differ from the OECD model rules; entities must map these to their group structure.
- Data Readiness Gap: Most groups lack automated processes to compute GloBE income, covered taxes, and substance-based income exclusion (SBIE) at the entity-jurisdiction level; technology enablement is critical.
- Interim Compliance Steps: Immediate actions include entity classification, constituent entity mapping, and scenario modeling for top-up tax liability to inform 2026 financial statements and tax provisioning.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement