A draft reported by KPMG Poland on 8 September 2026 would temporarily increase corporate income tax for the largest energy and fuel companies from 2027. Separately, the Council of Ministers has approved a bill implementing the first part of the European Union’s VAT in the Digital Age package, with changes scheduled for 1 January 2027.
Neither measure is yet binding. Both must complete Poland’s legislative process, including consideration by the Sejm and Senate, presidential action and publication in the Journal of Laws.
The proposed corporate income tax, or CIT, increase would apply to entities in the energy and fuel sectors with revenue exceeding EUR 50 million. The brief does not specify the accounting period or exchange-rate method used to test that threshold.
Under the proposal, affected companies would face a 30 per cent CIT rate in 2027. The rate would then fall to 26 per cent in 2028 and 23 per cent in 2029.
For investors, the proposed sequence matters because it could affect after-tax earnings and cash generation over three reporting years. Its practical effect would depend on the final legislation, each company’s taxable income and whether the scope or rates change during parliamentary consideration.
The temporary rates should not yet be incorporated as settled law. The government may amend the draft, while parliament can alter or reject provisions before the bill reaches the president.
The separate value added tax, or VAT, bill concerns Poland’s implementation of the first tranche of ViDA, the EU’s VAT in the Digital Age programme. Regfollower, citing a government release dated 2 September, said the amendment would clarify e-commerce rules and simplify selected cross-border procedures.
The planned changes cover the One Stop Shop and Import One Stop Shop, known respectively as OSS and IOSS. These systems allow qualifying businesses to account for VAT connected with certain cross-border consumer sales through simplified registration and reporting arrangements.
The bill would adjust the treatment of distance sales and make the EUR 10,000 business-to-consumer threshold more practical. The supplied sources do not provide the complete revised test or explain how the threshold would apply to an individual seller.
It would also redefine the moment when VAT becomes due for transactions processed through OSS and the non-EU OSS framework. Timing rules can affect when a business reports and pays tax, although the brief does not provide the proposed statutory wording.
Utilities are another part of the package. The amendment would expand simplified VAT settlement arrangements for supplies including electricity, heat, cooling and natural gas. This makes the bill relevant beyond e-commerce platforms to companies and investors following Poland’s energy and utility markets.
A later change is planned for 1 July 2028. Authorities intend to retire the existing call-off stock procedure and replace it with TOOG, or transfer of own goods, as a unified framework for recording intra-EU movements of company-owned goods through OSS.
The two proposals point to different elements of Poland’s developing tax policy. The energy measure would place temporarily higher corporate tax rates on large businesses in selected sectors. The ViDA bill would change the administration and timing of VAT for digital, cross-border and utility transactions.
KPMG also identified several court decisions that are already relevant to tax assessments. A Supreme Administrative Court ruling found that documentation issued by a courier company may serve as evidence supporting the zero per cent VAT rate for exports.
Other judgments addressed the treatment of promotional donations and employee cars under the Estonian CIT system. Unlike the proposed energy rates and ViDA amendments, these decisions have already been issued and may affect how existing tax rules are interpreted.
The distinction between proposals and current case law is central. Investors can treat the court rulings as part of the present tax environment, while the proposed CIT rates and VAT reforms remain subject to further legislative action.
