Updates · 29 September 2026
New Ministry of Finance Proposal: PIT, CIT and Lump-Sum Tax from 2027
The Ministry of Finance has prepared proposed changes to PIT, CIT and lump-sum taxation intended to take effect on 1 January 2027. The main aim is to ease the PIT burden on middle-income taxpayers and fund the resulting revenue shortfall through higher charges on the highest earners and largest businesses.
We summarise the key changes below. The bill is at the public consultation stage, scheduled for 21 days in the third quarter of 2026, and may change during the legislative process. Dates and rates reflect the draft of August 2026.
01
PIT: Removing the “Cliff Edge” and Introducing a 24% Intermediate Rate
The current tax scale has two rates, 12% and 32%, and a single threshold of PLN 120,000. Crossing it means an immediate 20-percentage-point increase in the marginal rate. The proposal replaces this with three bands:
- up to PLN 130,000 — 12%, less a tax reduction of PLN 3,600,
- PLN 130,000–150,000 — 24% on the amount above PLN 130,000,
- above PLN 150,000 — 32% on the amount above PLN 150,000.
What This Means in Practice:
- the first threshold rises from PLN 120,000 to PLN 130,000,
- a gentler 24% rate is introduced for income between PLN 130,000 and PLN 150,000,
- the 32% rate will apply only to income above PLN 150,000,
- the tax-free allowance remains PLN 30,000.
The Ministry estimates that approximately 3.5 million taxpayers will benefit, with average savings of about PLN 2,900 per year. Relief will be felt during the year through lower advance payments.
02
Solidarity Levy: An Increase from 4% to 5%
The so-called levy on the wealthiest taxpayers, covering annual income above PLN 1 million, will increase from 4% to 5% on the excess over that amount. It affects a narrow group of around 39,000 high-income individuals.
Under the proposal, the new rate will first apply to the levy payable by 2 May 2028 on income for 2027.
03
CIT: A New 22% Rate for the Largest Businesses
The current standard CIT rate is 19%. The proposal introduces a 22% rate for the largest taxpayers, whose revenue in the previous year exceeded EUR 50 million. It is also intended to cover tax capital groups and entities in domestic and international groups with group revenue of at least EUR 750 million.
Banks are excluded from this threshold because they are subject to separate, higher rates of 21–23%. The change will affect around 4,600 individual taxpayers and 87 capital groups.
Businesses making simplified advance payments will add 15.8% to those payments to reflect the higher rate during the year. Smaller CIT taxpayers, including those using the 9% rate, remain under the existing rules.
04
Lump-Sum Tax: A Significant Restriction of Preferential Treatment
These changes will have the greatest impact on high-revenue businesses:
- The eligibility limit falls from EUR 2 million to EUR 250,000 — a return to the original principle that this form of taxation is intended for small businesses.
- A higher 17% rate is introduced for revenue earned during the year in excess of EUR 300,000.
The EUR 50,000 gap between the EUR 250,000 eligibility limit and the EUR 300,000 higher-rate threshold provides a buffer for business planning. The Ministry estimates that the change will affect around 43,000 taxpayers, 2% of all lump-sum taxpayers, mainly in construction, trade, processing and healthcare.
If you have questions about the proposals and would like to review your legal and tax position, our firm is available to help. We will examine your particular circumstances and develop an individual strategy for addressing the proposed fiscal burdens.
This information does not constitute a legal opinion. For further information or legal assistance, please contact our firm: 42 207 66 66, kancelaria@krs-adwokaci.pl.
Contact
Do You Have Questions about This Topic?
We will be happy to explain what these changes mean for your business and which steps you may wish to take. Get in Touch — by telephone or email.