On 20 February 2025, a meeting between IGCC member companies and representatives of the Ministry of Finance was held at the CCIFP headquarters.
Participants from the Ministry of Finance (MF) included:
- Jarosław Neneman, Undersecretary of State
- Jarosław Szatański, Director of the Department of Income Taxes
- Łukasz Pepliński, Deputy Director of the Department of the Tax System
During the meeting, we discussed the following topics:
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Changes in the area of tax scheme reporting (MDR) – MF representatives confirmed that a draft of changes in this area is already prepared and will soon be presented for public consultation. The draft consists of several dozen pages and nearly a hundred pages of justification. It was also indicated that, through "various means," the commitment to effectively reduce the tax scheme reporting obligation by approximately 70% will be implemented (e.g., a white list). The proposed project will also include changes to the Tax Ordinance (including the statute of limitations for tax liabilities and the structure of powers of attorney).
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Separate legislation will address the elimination of the obligation to prepare a tax strategy and tightening measures in CIT and PIT concerning family foundations – with a probable effective date of January 2026.
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Withholding Tax (WHT) – A draft of guidelines regarding the so-called Look-Through Approach (LTA) is essentially ready, with final adjustments being made to the explanations concerning the beneficial owner requirement (expected within the coming weeks). Importantly, the Ministry did not rule out legislative changes in the area of WHT, which IGCC has long been advocating for.
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Global Minimum Tax (GLoBE) – Consultations on the R&D relief start tomorrow. The proposed changes will impact the relief as a whole (not only for companies applying it under GLoBE). According to MF, it cannot be ruled out that alignment with the GLoBE regime will bring modifications to its attractiveness. The consultation schedule for the PSI regime is not yet known. We should also expect ongoing amendments to the act, incorporating new OECD guidelines. The Ministry also highlighted a special task force on GLoBE, which is working on preparing the local GIR (GloBE Information Return).
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Tax solutions introduced under the Polish Deal – The Ministry plans to review the solutions implemented under the so-called Polish Deal, assessing their effectiveness (e.g., tax on shifted income) and attractiveness, such as the Polish holding company regime.
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Deregulation – MF representatives expressed openness to identifying and addressing tax compliance burdens that may be unnecessary from an entrepreneur's perspective.
Regarding point 6, within IGCC, we would like to propose launching a process to collect tax-related concerns regarding issues that you consider burdensome at the technical or operational level. Given what was discussed in the meeting with MF, we believe that now is a good time to raise such concerns and establish a dialogue with the Ministry.
In particular, the reported concerns could relate to:
- Burdensome reporting / compliance obligations (especially where tax authorities already have or could have access to the relevant information).
- Formal obligations such as unnecessary recurring notifications or declarations to tax authorities every year or quarter (instead, adopting the principle of reporting only in case of changes).
- Operational issues that hinder business activities (e.g., repealing the institution of general powers of attorney, as mentioned during the meeting).
- Legislative provisions that unnecessarily restrict access to certain tax preferences.
- Other issues.
CCIFP offers to coordinate the collection of these concerns, prepare a summary, and present them at a dedicated meeting before submitting them to the Ministry of Finance as a joint position.
Interested parties are invited to submit their concerns by March 20, 2025, to: justyna.smolak@ccifp.pl.
