Poland passes 22% corporate tax rate tied to Pillar Two group status

Poland’s Parliament has completed passage of a bill that would raise the ordinary corporate income tax rate from 19% to 22% for two classes of taxpayer. One is a taxpayer whose Polish revenue in the preceding tax year exceeded EUR 50 million. The other is a taxpayer that, at any time in the preceding tax year, was a constituent entity of a domestic or multinational group within the scope of Poland’s Global Minimum Tax Act.

The official parliamentary record for Sejm Print 3293 shows that the Sejm passed the bill on 5 November 2026 and the Senate approved it without amendment on 6 November. The bill was sent to the President on 6 November. It has not yet been signed or promulgated.

What the bill would change

Article 2 of the final text passed by Parliament would add Article 19(1)(6) to the Corporate Income Tax Act. The new provision sets a 22% rate and makes the EUR 50 million revenue test and the Pillar Two group-status test alternatives. A Polish entity can therefore fall within the higher rate even where its own revenue is below EUR 50 million if it was within a GloBE group in the preceding tax year.

The special rules in existing Article 19(1)(3) and (4) would take priority over the new 22% rate. For a tax capital group, the conditions would be tested by reference to its member companies. The revenue threshold would be converted into zloty using the National Bank of Poland rate on the last business day of the relevant revenue year and would be adjusted for tax years shorter or longer than 12 months.

Pillar Two status is a scope trigger, not the tax being amended

The cross-reference is to Article 4 of Poland’s Top-up Tax Act. That provision applies the Polish GloBE regime to groups that meet the EUR 750 million consolidated-revenue test in at least two of the four preceding fiscal years. Under the bill, that status in the preceding tax year would independently trigger the 22% ordinary CIT rate.

The bill does not amend Poland’s IIR, UTPR, QDMTT, GIR, safe-harbour or top-up-tax filing rules. It uses Pillar Two scope as an eligibility condition for a separate corporate-income-tax measure. Poland’s current ordinary CIT rate remains 19% until the bill completes the legislative process and the proposed application date is reached.