Poland Issues Draft Pillar 2 Notifications and Top-Up Tax Returns

On September 11, 2025, the Polish Ministry of Finance issued the draft Pillar 2 notifications and top-up tax returns (as XSD files) for consultation. The consultation lasts until September 19, 2025.

The notifications/returns issued for consultation are:

Initial Phase of International Activity Notification

Section 129(4) of the Polish Minimum Tax Law provides that an in-scope group is required to notify the Polish tax authorities of the the commencement of the initial phase of international exemption (where applicable) by the end of the 15th month following the end of the tax year (18 months in the transition year). 

The consultation issues Draft Form GLB-Z1 for this. 

Double Filing Relief Notification

Section 133(4) of the Polish Minimum Tax Law provides that where a GIR is filed in a foreign jurisdiction by a UPE or designated foreign filing entity and there is a qualified exchange of information agreement in place, the Polish filing entity is required to submit a notification to the Polish tax authority within 15 months following the end of the tax year (18 months in the transition year). 

The consultation issues Draft Form GLB-Z2 for the notification. 

Designated Filing Entity Notification

Article 135(1) of the Polish Minimum Tax Act provides that if there are at least two constituent entities of the group located in Poland,  they may choose one designated entity for tax return filing and payment purposes. The election can be made for a fixed period of no longer than 5 years. and can be repeated. Taxpayers wishing to make the election need to file a notification by the top-up tax return filing deadline.

The consultation issues Draft Form GLB-Z3 for this notification. 

IIR/UTPR Top-Up Tax Return

Article 134(1) of the Polish Minimum Tax Act requires submission of additional self- assessment returns for the IIR and UTPR by the end of the 18th month following the end of the tax year (the 21st month for the first transitional year).

The consultation issues Draft Form GLB-I1 for the IIR Return and Form GLB-U1 for the UTPR Form. 

QDMTT Top-Up Tax Return

Article 134 of the Law also requires submission of a DMT self- assessment return by the end of the 18th month following the end of the tax year (the 21st month for the first transitional year).

The consultation issues Draft Form GLB-D1P for the QDMTT Return.